Review of Waste Management Regulations and Requirements from

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World Bank Group

Prepared for U.S. Department of Energy

National Energy Technology Laboratory under Contract W-31-109-Eng-38

and ChevronTexaco Energy Research & Technology Company

Acting on behalf of the Petroleum Environmental Research Forum

Prepared by

Markus G. Puder and John A. Veil Argonne National Laboratory

December 2004

Waste Management Requirements ii

Argonne National Laboratory, a U.S. Department of Energy Office of Science laboratory, is operated by The University of Chicago under contract W-31-109-Eng-38.

DISCLAIMER This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor The University of Chicago, nor any of their employees or officers, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof. The views and opinions of document authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof, Argonne National Laboratory, or The University of Chicago.

Available electronically at http://www.osti.gov/bridge/

Available for a processing fee to U.S. Department of Energy and its contractors, in paper, from:

U.S. Department of Energy Office of Scientific and Technical Information P.O. Box 62 Oak Ridge, TN 37831-0062 phone: (865) 576-8401 fax: (865) 576-5728 email: [email protected]

Waste Management Requirements 1

REVIEW OF WASTE MANAGEMENT REGULATIONS AND REQUIREMENTS FROM SELECTED JURISDICTIONS

BACKGROUND Major oil companies operate in many countries around the world. The process of exploring for and producing oil and gas generates many kinds of wastes. Some of these wastes are inherently part of the exploration and production (E&P) process. Other wastes are generic industrial wastes that are not unique to E&P activities. Still other wastes are associated with the presence of workers at the site. All of these wastes must be appropriately managed by oil companies. A more detailed discussion of the types of wastes generated at E&P sites is included below. Some host countries have mature environmental regulatory programs that allow various waste management options, based on the characteristics of the wastes and the environmental settings of the sites. Oil companies also operate in countries where allowable waste management options are limited or very stringent and burdensome. In some cases, regulations do not exist at all. Companies operating in these countries can be confronted with limited and expensive waste management options. This report represents the first phase of a project designed to develop a framework that can be used as waste management guidelines for companies operating in areas that are not covered by detailed requirements. The guidelines may also be used as the basis for advocating future desired regulations in countries that do not currently have comprehensive waste management requirements in place. The Petroleum Environmental Research Forum (PERF)1 and the U.S. Department of Energy (DOE) jointly funded this first phase of the project. PERF will fund the remainder of the project to develop model waste management guidelines that can be used in cases where comprehensive waste management guidelines are not available. SCOPE OF REPORT The first phase of the project was designed to develop a sense for the range of requirements that are currently being used in developed countries and other jurisdictions, including international organizations. Representatives of PERF selected the jurisdictions whose waste management regulations and requirements would be reviewed for this project. The countries and political subdivisions selected include: the United States, the State of Louisiana, South Africa, Canada, and the Province of Alberta. PERF recommended that the World Bank Group be used as an example of international multilateral organizations.

1 PERF is a non-profit organization created in 1986 to provide a stimulus to and a forum for the collection, exchange, and analysis of research information relating to the development of technology for health, environment & safety, waste reduction, and system security in the petroleum industry. PERF generally operates through joint projects that are voluntarily joined by PERF members on a project-by-project basis. For this project, Argonne was contracted by ChevronTexaco, which acted on behalf of PERF. The other PERF members who joined this particular project include ExxonMobil, Unocal, Total, Statoil, and Halliburton.


The report consists of a short introduction followed by separate appendices for each jurisdiction. Each appendix discusses the agencies that have jurisdiction, the major laws that govern waste management, the classification of waste types, and summaries of the applicable regulatory or administrative requirements and criteria used by the agencies. Although there are many other good candidate countries that could have been included, the project budget did not allow for review of additional jurisdictions. To the extent that additional funding becomes available in the future, this report can easily be expanded with additional appendices. The appendices are included in the following order: Appendix 1: United States of America Appendix 2: Louisiana Appendix 3: South Africa Appendix 4: Canada Appendix 5: Alberta Appendix 6: World Bank Group TYPES OF WASTES GENERATED AT E&P SITES The E&P process involves many steps and activities (e.g., identification of hydrocarbons, exploratory drilling, site construction, development and production, decommissioning, and general maintenance throughout). Substantial volumes of waste materials can be generated throughout these phases. The largest portion comes from materials removed from the subsurface. For the sake of better focusing this report, we generically grouped waste materials from the E&P segment of the oil and gas industry into three main categories:

• Waste materials that are uniquely associated with E&P (E&PW), including drilling muds, drill cuttings, well completion fluids, workover fluids, stimulation fluids, production testing materials (hydrostatic test water), produced water, produced sand, naturally occurring radioactive materials (NORM), flare and vent gas, tank or pit bottoms, and deck drainage, among others.

• Industrial waste (IW) materials that can be present at an E&P site, but are not unique or

specific to E&P operations. Examples include construction materials, wood pallets, cardboard, insulating materials, plant equipment, sludges, batteries, fluorescent bulbs, coolant and antifreeze, filters, hoses, lines and cables, vehicle wastes, tires, excess drilling chemicals and containers, fuel storage containers, power unit and transport wastes, scrap metal, lubricating oils, sandblasting grit, paints, and solvents.

• Other waste (OW) materials derived from human and camp activities, include sanitary

wastes, domestic wastes (kitchen wastes, laundry wastes, light bulbs, sink and shower drainage), medical waste, and general municipal trash.


These categories do not necessarily reflect regulatory distinctions, but serve as functional groupings. The regulations from the different jurisdictions do not always distinguish between individual wastes or subdivide them in the same fashion. Table 1 presents a list of various waste materials that may be generated at E&P sites. The materials, which are listed in alphabetical order, are accompanied by their respective categories, source activities, and source types. Although this list includes many waste types, it is possible that wastes not listed here may also be found at E&P sites. This list is intended to frame the universe of wastes that will be considered in the current study effort. Table 1 Waste Materials Generated at E&P Sites

Waste Materials Categories Source Activities Source Types Absorbent material/spill pads

IW General maintenance, spill response

Solvents, production chemicals, and hydrocarbons

IW

Cleaning, well operations Cleaner acids, vessel cleaners, engine block flushing agents, engine cleaners

Acid/caustic solutions

E&PW Well operations Fracturing acids, completion and workover fluids

Activated carbon IW Water treatment, gas treatment, vapor recovery

Discarded activated carbon, discarded charcoal

Amine & amine sludges

IW Treatment and reclamation units and storage tanks

Solutions and sludges used to absorb carbon dioxide and hydrogen sulfide

Asbestos-containing materials

IW Buildings, vehicles

Materials containing more than 1% asbestos, building insulation and fireproofing, vehicle brakes and clutch pads

Ash IW Incineration Post-combustion residues Ballast water IW Tankers with non-segregated

ballast Hydrocarbons

Batteries IW Powering vehicles, engines, emergency systems, instruments, small equipment

Types include spent nickel-cadmium-lithium, mercury cell, and lead-acid

Blasting sand materials

IW Cleaning, rust removal Black beauty, silica sand (with paint chips), other abrasive materials

Boiler/cooling tower blowdown

IW Steam generation, cooling Scale inhibitors, biocides, corrosion inhibitors, heavy metals, solids

Catalyst IW Chemical manufacturing Substances that increase the rate of a chemical reaction, and maybe recovered at end

IW Construction and maintenance Heavy metals, thinners, viscosifiers Cement and concrete (slurries, mix water, returns)

E&PW Drilling operations (cement fragments dislodged by bit during casing), completion and workover operations

Heavy metals, thinners, viscosifiers

IW Spill recovery, cleanup Various Chemical/water mixtures

E&PW Hydrotesting Biocides, corrosion inhibitors, additives, residual hydrocarbons


Waste Materials Categories Source Activities Source Types IW At all stages Process chemicals, lab solvents Chemicals

(unused or spent) E&PW Drilling operations Fluid additive (corrosion inhibitors, biocides, anti-foulants, metals, surfactants, emulsifiers, organics, scavengers)

Construction debris IW Construction, maintenance, and turnaround

Mostly inert materials, including pallets and wood, metal, glass, insulation, scraps, by-products

Containers IW

Storage, transportation Metal and plastic barrels, drums, pails, and cans

Domestic waste/trash

OW Kitchen, bathroom, laundry, warehouse, offices

Food wastes (scraps, glass jars, tin and aluminum cans), paper, envelopes, office supplies, cardboard and packaging materials, disposal plates, cups, utensils, light bulbs

Drilling fluids (muds and cuttings)

E&PW Drilling wells, performing workovers

Diesel and mineral-oil based muds, water-based muds (include brine), and synthetic muds, rock particles

Drum rinse IW Cleaning From lube, chemical, pesticide containers Fiberglass IW Insulation

Products made of or with glass fibers or glass flakes

Filter: air, water IW Removal of solids and impurities Sock, cartridge, or canister-type filters, including air filters (compressors, turbines, vehicle engines), instrument filters, water treatment units, potable and service water systems, freshwater intakes, desalination units

Filter: contaminated IW Removal of solids and impurities Sock, cartridge, or canister-type filters, including lube oil filters, upstream injection water cartridges, oil filters, fuel and fuel gas filters, mercury removal unit filters, acid gas removal unit filters

Fluorescent bulbs IW Building maintenance, parking lot, roadway maintenance, exterior and interior lighting

Tubes, halogen lamps, other mercury-containing bulbs

Glass

IW, OW Various Laboratory glassware, chemical containers, plate glass from housing and vehicle windows

Glycol and antifreeze

IW Dehydration, antifreeze Solutions and sludges (ethylene, diethylene, triethylene, and tetraethylene glycol)

Hydrocarbon-impacted debris

IW Routine operations, spill response

Oily rags, clothing and gloves, oily equipment and pump packaging, wood hoes, rakes, and shovels

Hydrocarbon: water mixtures

IW Contact, spill recovery Vehicle and equipment oily wash water, tank bottoms, water with oil and emulsions (spill recovery/cleanup)


Waste Materials Categories Source Activities Source Types Ion exchange resin IW Ion removal from water Spent anion, cation, and mixed resins Medical waste OW Clinical procedures Bandages, gauze, and other materials with

body fluids; specimen and lab cultures; plastic syringes and tubing; needles; and glass

Mercury-containing equipment

IW Surplus, various devices Thermostats, thermometers, switches, meters

Merox sand

IW Running Merox unit Sand filters not fouled with caustics and hydrocarbons

NORM

E&PW Scale and sludge removal from equipment (production tubing, wellheads, flowlines, separators, and heaters/treaters)

Natural radioactivity at trace concentrations in underground formations and oil and gas production streams that exceeds background levels

Oil: used IW Oil changes in context of lubrication and similar

Petroleum-based lubricating greases, lube oil, motors and transmission oil, hydraulic fluids as well as synthetic oils

Paint wastes IW Construction, maintenance, and turnaround

Liquid and semi-liquid thinners, coatings, lacquers, and varnishes

PCB-containing equipment

IW Various Transformers, capacitors, switches, voltage regulators, rectifiers, light ballasts

PCB oil IW Running electrical equipment and similar

Oil from oil-filled transformers, capacitors, switches, voltage regulators, rectifiers, light ballasts, occasionally in hydraulic oils and heat transfer systems

IW Various Packaging material, plastic drums and containers, gaskets

Plastic and rubber

OW Various (living quarters) Packaging, plastic containers, plastic utensils

Produced sand E&PW Drilling, production Hydrocarbons, heavy metals, NORM Produced water

E&PW Production Inorganic salts, heavy metals, solids, production chemicals, hydrocarbons, benzene, PAHs, NORM

Pyrotechnics

IW Various Signal flares, smoke canisters, firing caps, and explosives

Refractory

IW Combustion Protective lining that resists high temperatures in heaters, boilers, and incinerators

Sanitary waste OW Sanitary facilities (workplace, living quarters)

BOD, coliform bacteria, treatment chemicals

Scrap metal IW Various Sheet metal, piping, tubing, wire, cable, empty drums/containers, tanks, pump housings, valves, fittings, vehicle/equipment parts


Waste Materials Categories Source Activities Source Types Silica/alumina desiccants

IW Various Adsorption material, including molecular sieve beds, instrument air driers

Sludge: chemical IW Maintenance and turnaround of vessels

Tank bottoms, including scrubber sludge, amine, and glycol sludges

Sludge: domestic sewage

OW Treatment unit Sludge consisting of the bio mass removed to remain in the sewage treatment unit (biological treatment unit, marine sanitation device)

Sludge: hydrocarbon E&PW Storage, treatment, recovery equipment

Tank bottoms, pit sludges, pigging wastes, paraffin

Sludge: leaded

IW Cleaning, decommissioning of equipment

Sludge, solids, or sediments impacted by leaded gasoline or lead additives (tetraethyl lead, tetramethyl lead)

Sludge: metals IW Cleaning, decommissioning of equipment

Sludge, solids, or sediments impacted by metals

Soil: chemicals-impacted

IW Operations and maintenance, accidents

Acids, caustics, sour caustics, spent/acid caustic (causing skin burns), process chemicals (e.g., amines), treatment chemicals (e.g., corrosion inhibitor, scavengers, anti-foulants, biocides)

Soil: hydrocarbon- impacted

IW Operations and maintenance, accidents

Crude oil, gas and lube oils, product or volatile fuels, hydrocarbon-based solvents, hydrocarbon-based well chemicals, vehicle equipment fluids

Solvents: halogenated

IW Cleaning and degreasing of parts and equipment

Fluorine, chlorine, bromine, iodine

Solvents: non-halogenated

IW Cleaning and degreasing of parts and equipment

Petroleum-based solvents like kerosene, Varsol, pain thinner or stripper, gasoline, toluene and xylene

Tank bottoms See Sludges

See Sludges See Sludges

Tires IW Automotive and equipment maintenance

—

Appendix 1: United States 1-1

APPENDIX 1: UNITED STATES OF AMERICA The United States ranks among the largest oil and gas producers in the world. The following sections describe the federal requirements governing the management of wastes generated in connection with onshore and offshore E&P operations. 1.1 AGENCIES WITH JURISDICTION OVER WASTE MANAGEMENT

OPERATIONS

The U.S. Environmental Protection Agency (EPA) is entrusted with protecting human health and safeguarding the natural environment — air, water, and land. The EPA works with other federal agencies, state and local governments, and Native American tribes to develop and enforce regulations under existing environmental laws. The EPA, responsible for researching and setting national standards for a variety of federal environmental programs, delegates to states and tribes the responsibility for issuing permits and monitoring and enforcing compliance. Where national standards are not met, the EPA can issue sanctions and take other steps to assist the states and tribes in reaching the desired levels of environmental quality. Programs not delegated to the states are managed through the EPA’s regional offices in direct implementation. In addition to the various Headquarters program offices, the EPA maintains 10 regional offices and 17 laboratories across the country. The Bureau of Land Management (BLM), a bureau of the U.S. Department of the Interior (DOI), has jurisdiction over onshore leasing, exploration, development, and production of oil and gas on the federal mineral estate. In addition, the BLM approves and supervises most oil and gas operations on Native American lands. The Minerals Management Service (MMS), a DOI bureau, is the federal agency that manages the nation’s natural gas, oil, and other mineral resources on the Outer Continental Shelf (OCS). The major federal laws that deal with waste materials and management activities include the Resource Conservation and Recovery Act (RCRA), the Clean Water Act (CWA), and the Safe Drinking Water Act (SDWA). The Code of Federal Regulations (CFR) is a codification of the rules published in the Federal Register by executive departments and agencies of the federal government. The CFR is divided into 50 titles representing broad areas subject to federal regulation. Environmental regulations are mainly offered in Title 40. Table A-1 provides a quick-reference synopsis of the major federal laws governing waste materials and management activities. Table 1-1 Federal Laws Governing Waste Materials and Management Activities

Law Material Subject of Regulation Activity Subject to Regulation RCRA Solid and hazardous wastes (unless

excluded or exempted) Generation, transportation, and treatment, storage, and disposal

SDWA Waste fluids or slurries Underground injection CWA Aqueous waste streams Surface discharge

Federal laws and regulations generally establish minimum federal standards. In light of the varying geological, climatological, ecological, topographic, economic, geographic, and age


differences among oil and gas drilling and production sites across the country, the laws and regulations of authorized states relative to oil and gas waste management operations exhibit differences in detail and scope when compared to the federal blueprint or other state programs. 1.2 WASTE CLASSIFICATION RCRA authorizes the EPA to regulate the management of wastes resulting from industrial, commercial, mining, agricultural, and community activities. RCRA’s system is based on two regulatory triggers. In general, a material must first be a solid waste. Once, and only if, it is established that the material is covered by the definition of solid waste, the next step involves assessing whether the solid waste is also a hazardous waste. Oil and gas E&P wastes have been exempted from coverage under the federal hazardous waste regulations. These wastes, however, are still subject to all other applicable federal and state laws and regulations.

• Trigger 1: Solid Waste. RCRA defines solid waste as “any garbage refuse, sludge from a waste treatment plant, water supply treatment plant, or air pollution control facility and other discarded material, including solid, liquid, semisolid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural operations, and from community activities, but does not include solid or dissolved material in domestic sewage, or solid or dissolved materials in irrigation return flows or industrial discharges….” The legal definition of a solid waste is based on the element of discard. The EPA’s regulations explain that discarded materials include abandoned, recycled, inherently waste-like, and certain other materials:

o Abandoned materials fall into three categories: (1) disposed materials, (2) burnt or incinerated materials, and (3) materials that are stored in lieu of being abandoned.

o Recycled materials include, subject to exceptions, certain secondary materials that are recycled in a particular fashion. The EPA establishes five types of used or residual waste-like materials: (1) spent materials, (2) sludges, (3) by-products, (4) commercial chemical products, and (5) non-excluded scrap metal. Recycling these materials pursuant to one of the following four activities may then trigger the solid waste definition: (1) use constituting disposal, (2) burning for energy recovery, (3) reclamation, and (4) speculative accumulation. The EPA has summarized its solid waste recycling definition in a table matrix that combines the five types of materials and the four activities.

o Inherently waste-like materials are: (1) dioxin wastes and (2) halogen-containing materials burned in halogen acid furnaces.

o Municipal solid waste, a subset of solid waste, includes durable goods (appliances, tires, batteries), nondurable goods (newspapers, books), containers and packaging, food wastes, yard trimmings, and miscellaneous organic wastes from residential, commercial, and industrial nonprocess sources.

• Trigger 2: Hazardous Waste. Under RCRA, hazardous waste means a “solid waste, or

combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may … cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness … or pose a substantial present or potential hazard to human health or the


environment when improperly treated, stored, or disposed of, or otherwise managed.” The EPA’s regulatory definition of hazardous waste, barring certain exclusions and exemptions, covers listed and characteristic wastes as well as certain waste mixtures and residues.

1.2.1 Hazardous Waste Exemption for Oil and Gas E&P Wastes In 1980, the U.S. Congress conditionally exempted E&P wastes from the hazardous waste management requirements of RCRA Subtitle C. In addition to directing the EPA to study these wastes and submit a report to Congress on the status of their management, Congress required the agency either to promulgate regulations under RCRA Subtitle C or make a determination that such regulations were unwarranted. In 1988, the EPA published its Regulatory Determination for Oil and Gas and Geothermal Exploration, Development, and Production Wastes in the Federal Register and, with it, lengthy lists of wastes determined to be either exempt or nonexempt. In 1993, the EPA published the Clarification of the Regulatory Determination for Wastes from the Exploration, Development, and Production of Crude Oil, Natural Gas, and Geothermal Energy in the Federal Register. With respect to petroleum production, primary field operations include activities occurring at or near the wellhead or production facility, but before the point where the custody of the petroleum is transferred from an individual field activity or centrally located facility to a carrier for transport to a refiner. Without a transfer of custody, the primary field operation ends at the last point of separation. Crude oil stock tanks are considered separation devices. The following list presents exempt E&P wastes:

• Activated charcoal filter media • Basic sediment and water (BS&W) • Caustics, if used as drilling fluid additives • Cement slurry returns and cement cuttings • Condensate • Cooling tower blowdown • Debris, crude oil soaked • Debris, crude oil stained • Deposits removed from piping and equipment prior to transportation (pipe scale,

hydrocarbon solids, hydrates, and other deposits) • Drill cuttings/solids • Drilling fluids/muds • Drilling fluids and cuttings from offshore operations disposed of onshore • Gases removed from the productions stream (H2S, CO2, and VOCs) • Liquid hydrocarbons removed from the production stream • Liquid and solid wastes generated by crude oil and tank bottom reclaimers • Oil, weathered • Paraffin • Pigging wastes from producer-operated gathering lines • Pit sludges and contaminated bottoms from storage or disposal of exempt wastes • Process filters • Produced sand • Produced water


• Produced water constituents removed before disposal • Produced water filters • Rigwash • Slop oil (waste crude oil from primary field operations and production) • Soils, crude oil contaminated • Sulfacheck/Chemsweet waste • Tank bottoms and basic sediment (BS&W) from storage facilities that hold product and

exempt waste (including accumulated materials such as hydrocarbons, solids, sand, and emulsion from production separators, fluid treating vessels, and production impoundments)

• VOCs from exempt wastes in reserve pits, impoundments, or production equipment • Well completion, treatment, stimulation, and packaging fluids • Workover wastes (blowdown, swabbing, and bailing wastes).

Nonexempt E&P wastes include those wastes that are not uniquely associated with an exploration and production activity, no matter where generated. All wastes that are not associated with primary field operations are nonexempt and subject to further scrutiny for purposes of classification. The following list presents nonexempt E&P wastes:

• Batteries, lead-acid • Batteries, nickel-cadmium • Boiler cleaning wastes • Boiler refractory bricks • Caustic or acid cleaners • Cement slurries, unused • Chemicals, surplus • Chemicals, unusable (including waste acids) • Compressor oil, filters, and blowdown waste • Debris, lube oil, contaminated • Drilling fluids, unused • Drums/containers, containing chemicals • Drums/containers, containing lubricating oil • Drums, empty (and drum rinsate) • Filters, lubrication oil (used) • Hydraulic fluids, used • Incinerator ash • Laboratory wastes • Mercury • Methanol, unused • Oil, equipment lubricating (used) • Paint and paint wastes • Pesticide and herbicide wastes • Sandblast media • Scrap metal • Soil, chemical-contaminated (including spilled chemicals) • Soil, lube oil-contaminated


• Soil, mercury-contaminated • Solvents, spent (including waste solvents) • Thread protectors, pipe dope-contaminated • Vacuum truck rinsate (from tanks containing nonexempt waste) • Waste in transportation pipeline related pits • Well completion, treatment and stimulation fluids, unused.

A nonexempt solid E&P waste is classified as hazardous if it has been listed as such by the EPA or if it is determined to exhibit a hazardous waste characteristic. In addition, certain waste mixtures and residues may be hazardous. 1.2.2 Listed Hazardous Wastes The EPA has published four lists: the F-, K-, P-, and U-Lists. Acutely hazardous waste is a subcategory of listed hazardous waste having particularly toxic properties and more stringent management standards for amounts exceeding 1 kg.

• F-List: hazardous wastes from nonspecific sources • K-List: hazardous wastes from specific sources • P-List: acute hazardous wastes • U-List: toxic wastes.

1.2.3 Characteristic Hazardous Wastes If a nonexempt oil and gas waste is not listed, it must be assessed for exhibiting one of the four hazardous waste characteristics — ignitability (for solid wastes displaying a flashpoint of less than 140oF), corrosivity (for solid wastes exhibiting a pH less than or equal to 2 or greater than or equal to 12.5), reactivity (for solid wastes being explosive or reacting violently with water), and toxicity (solid wastes containing one or more identified constituents at a level equal to or greater than the regulatory threshold when running the Toxicity Characteristic Leaching Procedure (TCLP), a laboratory test to determine leaching potential). Examples of ignitable nonexempt E&P waste may include certain cleaning solvents (which may also be listed), degreasers, pigging wastes, and paint wastes. Certain acid or caustic cleaning wastes, unused well acidizing fluids (that have not been downhole), rust removers, and waste battery acid may fall under the corrosivity characteristic. Waste oxiders may meet the reactivity characteristic. Examples of nonexempt E&P wastes that may fail the toxicity characteristic include unused pipe dope (lead), unused biocides (chromium), cleaning wastes or solvents (benzene), and pigging wastes (benzene). 1.2.4 Mixtures and Residues and Contained-In Policy The combination of any amount of a listed hazardous waste with a nonhazardous solid waste results in a listed hazardous waste. Under the EPA’s derived-from rule, certain residues from the treatment, storage, or disposal of a listed hazardous waste are hazardous wastes. Finally, any


environmental medium or debris that is contaminated by or contains a listed hazardous waste, or exhibits a characteristic, must be managed as if it were a hazardous waste. 1.3 WASTE MANAGEMENT REQUIREMENTS The federal E&P RCRA Subtitle C exemption does not preclude these wastes from control under other federal laws and regulations (as well as state laws and regulations, including oil and gas conservation programs and some hazardous waste programs). 1.3.1 Nonhazardous Waste Management Landfilling remains the predominant nonhazardous waste management method in the United States. (Other solid waste management methods include source reduction, recycling, and combustion.) A landfill means an area of land or an excavation in which wastes are placed for permanent disposal, and that is not a land application unit, surface impoundment, injection well, or waste pile. RCRA Subtitle D encourages states to develop comprehensive plans to manage nonhazardous industrial solid waste and municipal solid waste, sets federal criteria for municipal solid waste landfills (MSWLFs) and other solid waste disposal facilities, and prohibits the open dumping of solid waste. EPA-regulated waste management facilities include MSWLFs, non-municipal nonhazardous waste disposal units, and industrial solid waste (ISW) facilities:

• An MSWLF unit receives household waste, but may also receive other types of wastes as defined under RCRA Subtitle D, such as commercial solid waste, nonhazardous sludge, exempt small-quantity generator waste, and industrial solid waste. An MSWLF unit can be a new unit, an existing unit, or a lateral expansion. The EPA imposes national minimum requirements for MSWLFs with respect to their location, operations, design, groundwater monitoring, closure and post-closure care, corrective action, financial assurance, and recordkeeping.

• The EPA also imposes national minimum requirements for non-municipal nonhazardous

waste disposal units that receive hazardous waste from certain small-quantity generators that are conditionally exempt from most hazardous waste management requirements (below).

• For ISW facilities, including paper mill landfills, coal ash landfills, and construction and

demolition waste (C&DW) landfills, the EPA provides general performance requirements (for example, providing adequate protection to ground and surface waters). The EPA’s regulations do not prescribe specific design criteria for liner or cover systems for these facilities. In the Guide for Industrial Waste Management, the EPA recommends characterizing the potential risk to groundwater posed by a management unit before a liner system is chosen, designed, and installed.

1.3.2 Hazardous Waste Management RCRA authorizes EPA to regulate hazardous waste from generation to ultimate disposition (“cradle-to-grave”). Those who generate, transport, treat, store, or dispose of hazardous waste


are subject to the waste management rules promulgated under Subtitle C of RCRA. The management rules for universal waste and used oil are also promulgated under Subtitle C of RCRA. Universal wastes and used oil managed under specific rules receive regulatory relief from the more stringent, full hazardous waste management regulations.

1.3.2.1 Generator Requirements Generators must comply with some or all of RCRA’s hazardous waste generator rules, depending on the amount and type of hazardous waste generated monthly:

• Large-quantity generators generate greater than 1,000 kg of hazardous waste per calendar month; or greater than 1 kg of acutely hazardous waste per calendar month.

• Small-quantity generators generate between 100 kg and 1,000 kg of hazardous waste per

calendar month, and accumulate less than 6,000 kg of hazardous waste at any time.

• Conditionally exempt small generators generate less than 100 kg of hazardous waste per calendar month, or less than 1 kg of acutely hazardous waste per calendar month.

Generator responsibilities include identifying waste as hazardous, determining the volume of hazardous waste generated monthly, notifying the EPA of hazardous waste activities, obtaining an EPA identification (ID) number, storing the hazardous waste properly onsite in accordance with the management standards applicable to generators accumulating hazardous waste onsite without a permit, packaging the hazardous waste for shipment offsite, manifesting the shipment, developing and maintaining a contingency plan, training employees who manage hazardous waste, and preparing biennial reports and exception reports.

1.3.2.2 Transporter Requirements Persons or companies transporting hazardous waste are responsible for notifying the EPA of hazardous waste activities; obtaining an EPA ID number; complying with manifest requirements; complying with recordkeeping requirements; ensuring that the shipment has the appropriate labels, markings, and placards; and responding properly to releases of hazardous waste during transport. Transporters must comply with all applicable Department of Transportation (DOT) standards, including the requirements to register with DOT and train employees.

1.3.2.3 Requirements for Treatment, Storage, and Disposal Facilities (TSDFs) TSDFs treat, store, or dispose of hazardous wastes. RCRA identifies and regulates boilers and industrial furnaces, containers, containment buildings, drip pads, landfills, storage or treatment tanks, incinerators, land treatment facilities, surface impoundments, underground injection wells, and waste piles. Owners and operators of hazardous waste TSDFs must comply with all applicable hazardous waste management rules, including the preceding generator requirements, TSDF permit requirements, and the requirement to store the hazardous waste properly onsite in accordance with the storage unit’s management standards, TSDF inspection plan, facility


operating records, groundwater protection program, land disposal restrictions, financial responsibility standards, and closure and post-closure plans. EPA’s regulations for land disposal units cover landfills, surface impoundments, and waste piles. Surface impoundments are very similar to landfills in that both are natural topographic depressions, man-made excavations, or diked areas formed primarily of earthen materials such as soil. Surface impoundments are generally used for temporary storage or treatment. Waste piles, which are essentially noncontainerized piles of solid nonflowing hazardous waste, are temporary units not intended for final disposal of wastes. Since landfills typically serve as permanent disposal sites, the closure and post-closure requirements are somewhat different from those governing other land-based units. In addition to the unit-specific standards for land-based hazardous waste management, RCRA includes the land disposal restrictions (LDR) program. The LDR does not mandate physical barriers to protect groundwater, but instead requires that hazardous wastes undergo physical or chemical changes. The LDR requirements apply to all hazardous wastes (with a few exceptions) once a treatment standard has been established for the waste in question. The disposal prohibition prong of the LDR program prohibits the land disposal of hazardous waste that has not adequately been treated, to reduce the threat posed by such waste. The treatment standards are based on the performance of the best demonstrated available technology for a given waste. The LDR program also includes alternative treatment standards for unique waste streams such as lab packs, debris, and soil.

1.3.2.4 Universal Waste Requirements Universal wastes are subject to special management provisions intended to ease the management burden and facilitate the recycling of such materials. Four types of wastes are currently covered: hazardous waste batteries, hazardous waste pesticides that are either recalled or collected in waste pesticide collection programs, hazardous waste thermostats, and hazardous waste lamps. More wastes may be added in the future. The program includes regulatory provisions for universal waste handlers, transporters, and destination facilities. Handlers of universal wastes are responsible for notifying the EPA of universal waste activities, following waste-specific management standards, labeling and marking the universal waste itself or its container, adhering to accumulation time limits, training employees who manage universal wastes, following proper response actions for releases of universal waste, packaging the universal waste for shipment offsite, and tracking shipments. Although there are currently only four types of universal wastes in the federal program, states that have adopted the universal regulations are allowed to add additional wastes to their state lists of universal wastes without the prior addition of these wastes at the federal level.

1.3.2.5 Used Oil Management Requirements Used oil is regulated under its own recycling program. It is defined as any oil that has been refined from crude oil or any synthetic oil that has been used, and as a result of such use is contaminated by physical or chemical impurities. Depending on the category of handler, a handler of used oil must comply with a range of used oil management requirements. In many


instances, the activities of a handler of used oil will meet the criteria for more than one handler category, thereby subjecting the handler to additional requirements. Responsibilities include obtaining an EPA ID number; notifying the EPA of used oil activities; determining whether the used oil is “off-specification used oil” or “specification used oil”; testing used oil for halogen content; determining whether mixtures of used oil and hazardous waste are regulated under the used oil rules or the hazardous waste rules; storing the used oil properly onsite; packaging the used oil for shipment offsite; tracking used oil shipments; preparing various shipment records, reports, and plans; and following proper response actions for releases of used oil. 1.3.3 Medical Waste Management Medical waste is generally defined as any solid waste that is generated in the diagnosis, treatment, or immunization of human beings or animals, in research pertaining thereto, or in the production or testing of biologicals, including soiled or blood-soaked bandages, culture dishes and other glassware, discarded surgical gloves, discarded surgical instruments (scalpels), needles used to give shots or draw blood, cultures, stocks, swabs used to innoculate cultures, lancets, and others. The EPA has promulgated regulations governing emissions from hospital/medical/infectious waste incinerators as well as requirements under the federal Insecticide, Fungicide and Rodenticide Act (FIFRA) for medical waste treatment technologies that use chemicals for treating the waste. Medical waste disposal is regulated at the state level. 1.3.4 Injection Operations The Safe Drinking Water Act (SDWA) establishes the Underground Injection Control (UIC) program designed to protect underground sources of drinking water (USDWs). A USDW is an aquifer or portion of an aquifer that supplies any public water systems or contains sufficient quantity of groundwater to supply a public water system; currently supplies drinking water for human consumption or contains fewer than 10,000 milligrams/liter total dissolved solids; and is not an aquifer exempted from UIC regulations. For purposes of regulatory control, the EPA distinguishes between different classes of UIC injection wells:

• Class I wells inject hazardous (H) waste, nonhazardous (NH) industrial or municipal waste, and radioactive waste below the lowermost formation containing a USDW within one quarter mile of the well bore.

• Class II wells inject fluids associated with the production of oil and gas for disposal (D)

and enhanced recovery (ER).

• Class III wells inject fluids associated with solution mining of minerals. (This well class is not relevant for purposes of this study.)

• Class IV wells inject hazardous or radioactive waste fluids into or above USDWs. They

are generally banned unless authorized under other statutes for groundwater remediation.


• Class V wells — those not captured in the other well classes — most commonly inject nonhazardous fluids into or above a USDW. They typically include shallow, onsite disposal systems, such as floor and sink drains discharging directly or indirectly to groundwater, dry wells, leach fields, and similar types of drainage wells.

The EPA’s regulatory minimum requirements and technical criteria and standards for UIC injection wells include permitting; area of review analysis, mechanical integrity testing; construction, operating, monitoring, and reporting; and plugging and abandonment. Table 1-2 summarizes the requirements for the well classes of interest to this study.

Table 1-2 Summary of Federal Regulatory Requirements by Class of Injection Well

Class Permit

Requirement Life of Permit

Area of Review MIT Internal

MIT External

Other Test

Monitoring

Reporting

I H Yes, plus Land Ban Petition

Up to 10 years

2-mile minimum for hazardous waste wells

Pressure test annually and after each workover

Temperature or noise or other approved log at least every five years

Annual radioactive tracer survey and fall-off test, casing inspection log after each workover, continuous corrosion testing

Continuous injection pressure, flow rate, volume, temperature; annulus pressure, fluid chemistry, and groundwater monitoring, as needed

Quarterly

I NH Yes Up to 10 years

¼ mile minimum

Pressure or alternative test at least once every five years

Every five years

Annual fall-off test

Quarterly

II Yes Specific period up to life of well

New wells ¼ mile fixed radius or calcula-tion of zone of endanger-ment

Pressure test at least once every five years

Adequate cement records may be used in lieu of logs

Annual fluid chemistry and other tests as needed/required by permit

Injection pressure, flow rate, and cumulative volume (weekly for disposal)

Annual

IV Banned, unless authorized

Closed upon identi-fication, unless author-ized cleanup project

No new wells allowed except those that are part of a cleanup operation; EPA reviews and approves technical plans; monitoring for system performance may be necessary; contingency plan must be designed to be protective of human health

Closure or compliance report on schedule

V Authorized by rule (i.e., not permitted under federal rules)

Inventory requirements; ban of new large capacity cesspools and new motor vehicle waste disposal wells; phase-out process for existing large capacity cesspools and new motor vehicle waste disposal wells

Required for permit-ted wells; all wells must be inventoried


In U.S. offshore areas, operators may inject exempt E&P wastes that originate on the OCS into injection wells or encapsulate them in the well bore of wells that are about to be abandoned. Each application for underground waste disposal must be authorized on a case-by-case basis by the MMS. When exempt E&P wastes are injected into underground injection wells, the formation that receives the wastes must be located below the deepest underground source of drinking water, must be isolated above and below by shale layers, and may not contain any producing wells. Operators must demonstrate that injection wells have mechanical integrity. In addition, operators may use two types of encapsulation methods for exempt E&P wastes. The first type involves the placement of the wastes directly in the well bore of a well that is being abandoned. Under the second type, wastes are placed into a section of pipe, caps are put on both ends, and the pipe section is lowered into the well bore. 1.3.5 Discharge Operations The CWA requires that all discharges of pollutants to surface waters (streams, rivers, lakes, bays, and oceans) must be authorized by a permit issued under the National Pollutant Discharge Elimination System (NPDES) program. The two basic types of NPDES permits issued are individual and general permits. Individual NPDES permits are specifically tailored to individual facilities. General NPDES permits, issued by the EPA’s regional office, cover multiple facilities within a certain category located in a specific geographical area. General permits are used for nearly all offshore oil and gas discharges. Under the CWA, the EPA has published federal NPDES regulations. NPDES permit writers derive effluent limits from the applicable technology-based effluent limitation guidelines (ELGs) and water quality-based standards that address site-specific environmental effects of discharges. The more stringent of the two will be written into the permit. Discharges into territorial seas, contiguous zone, and the oceans must undergo yet an additional level of review, the so-called ocean discharge criteria evaluation, to ensure that they do not cause unreasonable degradation of the marine environment. Other NPDES permit conditions and responsibilities include sampling, recordkeeping, reporting, and preparation of best management practices plans or spill prevention plans. The EPA has codified the ELGs for oil and gas industry onshore, offshore, and coastal activities. Oil and gas activities located onshore and in coastal waters (except for Cook Inlet (Alaska), which is treated like the offshore category) may in general not discharge wastewater pollutants into navigable waters from any source associated with production, field exploration, drilling well completion, or well treatment — produced water, drilling muds, drill cuttings, and produced sand. (However, for certain onshore facilities located in the western continental United States, the EPA allows the discharge of produced water for agricultural use subject to a maximum oil and grease limit). In most cases, offshore oil and gas facilities may discharge, subject to limits. Some types of E&P wastes, however, cannot be discharged. These include oil-based drilling fluids and cuttings, produced sand, and NORM sludge and scale. The prohibition on NORM disposal does not apply to the NORM present in produced water. Table 1-3 offers a summary of the offshore discharge requirements.


Table 1-3 Summary of Requirements for Offshore Activities Waste Source Standard

Baseline Requirements: • No discharge of free oil or diesel oil (using

a static sheen test) • 96-hour LC50 >30,000 ppm (using

suspended particulate phase and EPA’s mysid shrimp toxicity test)

• Metals concentrations in the barite added to mud must not exceed:

o 1 mg/kg for mercury o 3 mg/kg for cadmium

No discharge of drilling wastes allowed within 3 miles of shore

Drilling wastes

Additional Requirements for Synthetic-Based Muds (SBMs):

• Whole muds may not be discharged • Cuttings with up to 6.9% SBMs may be

discharged • Ester SBMs can have up to 9.4% SBM on

cuttings • Polynuclear aromatic hydrocarbon (PAH):

Ratio of PAH mass to mass of base fluid may not exceed 1 × 10-5

• Biodegradation rate of chosen fluid shall be no slower than that for internal olefin

• Base fluids are tested using marine anaerobic closed bottle test

• Base fluid sediment toxicity shall be no more toxic than that for internal olefin base fluid

Produced water; treatment, workover, and completion fluids

Oil and grease limits before discharge • 29 mg/L monthly average • 42 mg/L daily maximum

ELGs for coastal waters require zero discharge except in Cook Inlet, Alaska

• Offshore limits for Cook Inlet

Produced sand No discharge

NORM sludge and scale No discharge (prohibition does not apply to NPRM present in produced water)

Domestic waste No discharge of foam and floating solids

Sanitary waste Floating solids: no discharge Residual chlorine: minimum of 1 mg/L and maintained as close as possible to this concentration


Four of the EPA’s regional offices have issued permits to facilities discharging into ocean waters beyond the three-mile limit of the territorial seas (Eastern Gulf of Mexico [Region 4], Western Gulf of Mexico [Region 6], California [Region 9], and North Slope and Cook Inlet, Alaska [Region 10]). The regional general NPDES permits impose additional operational, monitoring, testing, and reporting requirements. Not all types of waste materials are covered by the ELGs, but materials discharged from a facility must be included in the NPDES permit. For example, wastes such as cooling water, boiler blowdown, ballast water, and others are not mentioned in the ELGs, but the general permits authorize discharges of these wastes. The permit writer calculates limits for these other types of wastes on the basis of best professional judgment.

Appendix 2: Louisiana 2-1

APPENDIX 2: STATE OF LOUISIANA (USA) Louisiana, located in the southern part of the United States along the Gulf of Mexico coast, is one of the leading oil and gas producing states in the country. Louisiana has extensive production from onshore and coastal marsh locations, and also receives a large quantity of wastes from offshore facilities. The following sections describe how different types of wastes are regulated in Louisiana, with a special emphasis on the wastes that are directly part of the exploration and production (E&P) process. 2.1 AGENCIES WITH JURISDICTION OVER WASTE MANAGEMENT

OPERATIONS Under U.S. environmental law, many of the federal water and waste regulatory programs can be delegated by the U.S. Environmental Protection Agency (EPA) to state agencies. Louisiana has taken primacy for the Resource Conservation and Recovery Act (RCRA) solid and hazardous waste management programs, the Clean Water Act’s National Pollutant Discharge Elimination System (NPDES), and the Safe Drinking Water Act’s Underground Injection Control (UIC) programs. The state programs are very similar to those established by the EPA as national programs. The Louisiana Department of Environmental Quality (DEQ) administers most of the major environmental protection laws. Of particular interest to this report, the DEQ manages the solid and hazardous waste programs, the NPDES program, and has responsibility for managing wastes containing naturally occurring radioactive material(s) (NORM). The Louisiana Department of Natural Resources (DNR), Office of Conservation, has the responsibility for regulating the exploration and production of oil, gas, and other hydrocarbons, and administers the UIC program for injection of produced water and other E&P wastes. In November 2001, the DNR made a major revision to its E&P waste management regulations (known as Statewide Order 29-B). These are among the most comprehensive and current E&P waste management regulations in the states. The Louisiana Department of Health and Hospitals (DHH) regulates management and disposal of medical wastes. Medical waste could be generated to the extent that E&P operations have a medical clinic or facility for workers or local natives. 2.2 WASTE CLASSIFICATION Louisiana closely follows the federal waste classification described in Appendix 1. One important difference is that E&P wastes are regulated in Louisiana, whereas they are not specifically regulated at the federal level. They are exempted from Subpart C of RCRA, and based on EPA’s 1988 determination, they are left to the states for regulation. Most wastes found at E&P sites will be considered solid wastes under the Louisiana definition:


“Any garbage, refuse, or sludge from a wastewater treatment plant, water-supply treatment plant, or air pollution-control facility, and other discarded material, including solid, liquid, semisolid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural operations, and from community activities. Solid waste does not include solid or dissolved material in domestic sewage; solid or dissolved materials in irrigation-return flows; industrial discharges that are point sources subject to permits; source, special nuclear, or by-product material; or hazardous waste.”

Some types of solid wastes are not covered by Louisiana’s regulatory programs. The following solid wastes that are processed or disposed of in an environmentally sound manner are not subject to the permitting requirements or processing or disposal standards of the solid waste regulations:

• Wastes resulting from land and right-of-way clearing (trees, stumps) and disposed of on the site where generated;

• Solid wastes in facilities that have been closed in a manner acceptable to the

administrative authority prior to January 20, 1981;

• Materials such as waste papers, metals, and glass that are presorted to be recycled or reused and not destined for disposal;

• Uncontaminated earthen materials such as limestone, clays, sands, clamshells, river silt,

and uncontaminated residues from beneficiation of earthen materials; and

• Brick, stone, reinforced and unreinforced concrete, and asphaltic roadbeds. Any person or company subject to the DEQ solid waste regulations who generates, collects, stores, transports, processes, or disposes of solid waste may petition the DEQ for exemption from these regulations or any portion thereof. The DEQ may provide exemptions from these regulations or any portion thereof when petitions for such are deemed appropriate. Solid waste should not be stored long enough to cause a nuisance, health hazard, or detriment to the environment. Containers used for solid waste should prevent access by rodents and insects, minimize the escape of odors, and keep out water. Solid wastes can be subdivided into several other categories:

• E&P waste,

• NORM waste,

• Hazardous waste,

• Industrial solid waste,

• Residential solid waste, and

• Other wastes not specifically relevant to E&P activities.


Because of this report’s emphasis on E&P wastes, the E&P wastes and NORM associated with E&P waste are discussed in greater detail in the next few sections. The solid waste types that are not E&P wastes but could still be found at an E&P site are discussed after that. Medical wastes, while not solid wastes, represent another class of wastes that may be generated at an E&P site. They are briefly discussed at the end of the report. 2.3 WASTE MANAGEMENT REQUIREMENTS

2.3.1 E&P Wastes The primary focus of this report is on those wastes directly related to E&P processes. Under Louisiana rules, E&P wastes are regulated by the DNR under a set of requirements known as Statewide Order 29-B. Like many other states, Louisiana has regulated E&P wastes for a long period of time. Some sections of the regulations date back 60 years to 1943. These were modified and expanded over the decades. The most recent major changes to the regulations followed a waste management event that received attention in the national news media. In response to that event, the DNR began an extensive E&P waste-testing program in May 1998. The results of that testing program were used to conduct a comprehensive health risk analysis of commercial disposal operations, which was completed in 2001. The recommendations from the health risk analysis were incorporated into revisions to Statewide Order 29-B. The revisions became effective in November 2001. The DNR has continued to update and expand the E&P waste regulations. For example, new regulations for disposal of E&P waste into salt caverns were adopted in June 2003. The regulations allow operators multiple options for managing E&P wastes. Order 29-B contains three major chapters that outline E&P waste management requirements. Chapter 3 deals with onsite management of E&P wastes; Chapter 4 deals with Class II injection and disposal wells; and Chapter 5 deals with offsite management of E&P wastes. Note that although Chapter 3 uses the term “nonhazardous oilfield waste,” or “NOW,” rather than “E&P waste,” the terms are equivalent. To avoid confusion, the following discussion uses just the term “E&P waste.”

2.3.1.1 Definition and Description E&P waste is defined as drilling wastes, salt water, and other wastes associated with the exploration, development, or production of crude oil or natural gas wells that are not regulated by the provisions of, and therefore are exempt from, the Louisiana Hazardous Waste Regulations and the federal Resource Conservation and Recovery Act (RCRA). The DNR subdivides E&P wastes into the waste types shown in Table 2-1.

2.3.1.2 Onsite Management of E&P Wastes Within six months of drilling a well or performing a workover on a well, the operator must report to DNR the type and volume of E&P waste generated and how the waste was disposed of. Injection of E&P waste into an underground source of drinking water (USDW) or otherwise contaminating a USDW with E&P waste is prohibited. Produced water may be disposed of by subsurface injection or used for enhanced recovery into legally permitted wells. Produced water


or other E&P wastes cannot be injected into hydrocarbon-producing zones without prior approval by the DNR. Table 2-1 E&P Waste Types Waste Type

Waste Description

01 Salt water (produced brine or produced water), except for salt water whose intended and actual use is in drilling, workover or completion fluids or in enhanced mineral recovery operations, process fluids generated by approved salvage oil operators who only receive oil (BS&W) from oil and gas leases, and natural gas plant processing waste fluid that is or may be commingled with produced formation water.

02 Oil-base drilling wastes (mud, fluids, and cuttings)

03 Water-base drilling wastes (mud, fluids, and cuttings)

04 Completion, workover, and stimulation fluids

05 Production pit sludges

06 Storage tank sludge from production operations, onsite and commercial saltwater disposal facilities, salvage oil facilities (that only receive waste oil [BS&W] from oil and gas leases), and sludges generated by service company and commercial facility or transfer station wash water systems

07 Produced oily sands and solids

08 Produced formation fresh water

09 Rainwater from firewalls, ring levees, and pits at drilling and production facilities

10 Washout water and residual solids generated from the cleaning of containers that transport E&P waste and are not contaminated by hazardous waste or material — washout water and solids may be generated at a commercial facility or transfer station by the cleaning of a container holding a residual amount of E&P waste

11 Washout pit water and residual solids from oilfield-related carriers and service companies that are not permitted to haul hazardous waste or material

12 Nonhazardous natural gas plant processing waste solids

13 (Reserved)

14 Pipeline test water that does not meet discharge limitations established by the appropriate state agency, or pipeline pigging waste, i.e., waste fluids/solids generated from the cleaning of a pipeline

15 E&P wastes that are transported from permitted commercial facilities and transfer stations to permitted commercial treatment and disposal facilities, except those E&P wastes defined as Waste Types 01 and 06

16 Crude oil spill cleanup waste

50 Salvageable hydrocarbons bound for permitted salvage oil operators

99 Other E&P waste not described above — a description of these wastes and written approval from the Office of Conservation are required and must be attached to the manifest prior to transport

In the past, operators often used various types of onsite pits for storage and disposal of E&P wastes. The DNR has more recently prohibited the use of most types of pits at many locations in the state. Some types of pits are exempted from the prohibition, including compressor station pits, natural gas processing plant pits, emergency pits, and salt cavern pits located in the coastal


area, and reserve pits. Pits must have levees (walls or berms) that are built at least one foot higher than the 100-year flood level. The liquid level in the pits may not come within two feet of the top of the levees. Pits must be constructed with natural or synthetic liners. If natural liners are used, they must provide for hydraulic conductivity of no greater than 1 × 10 –7 cm/sec. If synthetic liners are used, they must meet the same hydraulic conductivity criteria as well as the following requirements:

• Pits must be constructed with side slopes of 3:1, • A sufficient excess of liner must be used in the pit to prevent tearing when the waste is

added,

• The thickness must be less than 10 mm,

• The breaking strength must be greater than or equal to 90 lb,

• The bursting strength must be greater than or equal to 140 lb,

• The tearing strength must be greater than or equal to 25 lb, and

• The seam strength must be greater than or equal to 50 lb. When pits are closed, operators may use onsite land treatment, burial, solidification, or other techniques approved by the DNR. Operators may also elect to transport the E&P wastes from the pits to an offsite commercial disposal facility. If the offsite disposal option is selected, the E&P waste must be transported under a shipping manifest. For any pit closure option other than subsurface injection, the operators must analyze the pit contents for the following parameters: pH, arsenic, barium, cadmium, chromium, lead, mercury, selenium, silver, zinc, oil and grease, electrical conductivity, sodium adsorption ratio, exchangeable sodium percentage, and cation exchange capacity. If the pit is located in a coastal area, radioisotopes must be monitored also. Closures of reserve pits at some shallow wells are exempted from the monitoring requirements. Closures of those reserve pits that are not exempted must meet numerical limits for most of these parameters. The numerical limits vary with the closure methods use, as shown in Table 2-2 below. Closure using burial (with or without solidification) must ensure that: the top of the buried soil/waste mixture is at least 5 feet below ground level and is covered with at least 5 feet of native soil, and the bottom of the burial cell is at least 5 feet above the seasonal high water table. Operators may also dispose of reserve pit fluids by injecting them into a newly drilled well that is about to be plugged and abandoned or into the casing annulus of the same well that was just drilled or worked over.


Table 2-2 Numerical Limits for Pit Closure Using Different Methods Parameter Land Treatment Burial or Trenching Solidification

pH range 6–9 6–9 6–12 Arsenic 10 ppm 10 ppm <0.5 mg/L a Barium (upland areas) 40,000 ppm 40,000 ppm <10 mg/L a Barium (submerged wetland areas)

20,000 ppm 20,000 ppm <10 mg/L a

Barium (elevated wetland areas)

20,000 ppm 20,000 ppm <10 mg/L a

Cadmium 10 ppm 10 ppm <0.1 mg/L a Chromium 500 ppm 500 ppm <0.5 mg/L a Lead 500 ppm 500 ppm <0.5 mg/L a Mercury 10 ppm 10 ppm <0.02 mg/L a Selenium 10 ppm 10 ppm <0.1 mg/L a Silver 200 ppm 200 ppm <0.5 mg/L a Zinc 500 ppm 500 ppm <5.0 mg/L a Oil and grease content <1% dry weight after

closure <3% by weight <10 mg/L a

Electrical conductivity <8 mmhos/cm b <4 mmhos/cm c

<12 mmhos/cm

Sodium adsorption ratio <14 b

<12 c

Exchangeable sodium percentage

<25% b

<15% c

Moisture content <50% by weight Chlorides <500 mg/L c Unconfined compressive strength

>20 psi

Permeability <1 × 10-6 cm/sec Wet/dry durability >10 cycles to failure a Measured by leachate testing according to a DNR-approved method. b Applies in elevated freshwater wetlands areas where the disposal site is not normally inundated. c Applies in upland areas. 2.3.1.3 Injection of E&P Wastes Most of the injection portion of Order 29-B deals with Class II injection wells used for disposing of produced water or for enhanced recovery. The DNR program follows the federal UIC program closely, so the details are not discussed here. Of greater interest is a relatively new section of Order 29-B that outlines extensive requirements for injecting slurries of ground-up solid E&P wastes at pressures that exceed the formation


fracture pressure. Slurry injection must be conducted using a dedicated injection well with tubing and packer and a downhole pressure sensor. The well must be carefully cemented and pressure-tested before injection is authorized. Operators must perform an area of review evaluation to determine that there are no other well bores, fault planes, or other pathways for injected materials to move upward to the surface or to a drinking water aquifer. Operators must also demonstrate that the injection zone is overlain by a containment zone at least 500 feet thick and a confining zone at least 50 feet thick. These must have appropriate thickness and permeability to keep fractures from moving upward and outward to undesirable endpoints. The permits require frequent logging tests and monitoring for bottom hole pressure, injection rate, annulus pressure, injected fluid density, cumulative volume of waste injected, and the origin, type, and components of the waste streams. Fracture heights and lengths must be evaluated at least every three months. Injection may only occur during daylight hours.

2.3.1.4 Offsite Management of E&P Waste Any E&P wastes taken offsite for disposal must be analyzed for at least pH, total petroleum hydrocarbons, electrical conductivity, benzene, sodium adsorption ratio, exchangeable sodium percentage, arsenic, barium, cadmium, chromium, copper, lead, mercury, molybdenum, nickel, selenium, silver, and zinc. A benzene limit of 3,198 mg/kg applies to storage tank sludges or natural gas plant processing waste solids, if they are taken to land treatment facilities. If a waste stream changes over time, it must be retested and characterized. Siting Requirements: Commercial waste management and transfer facilities are subject to specific siting requirements, as described below:

• They may not be located within one quarter mile of a public water supply well, 1,000 feet of a private water supply well, or within a source water protection zone established by the DEQ;

• They may not be located within 500 feet of residential, commercial, and public buildings,

churches, schools, and hospitals, unless waived by the owners of such structures. The 500-foot setback is waived for transfer stations located near commercial buildings;

• For Type A land treatment facilities, minimum setbacks are required, as shown in

Table 2-3;

• Any injection zones must include an adequate thickness and areal extent and have clay confining beds separating the top of the injection zone and the lowermost drinking water zone;

• E&P waste storage containers, land treatment cells, and sediment ponds may not be

located in flood hazard zones A or Z, unless there are levees constructed with an elevation at least one foot above the 100-year flood elevation;


• They may not be located on property designated as wetlands; and

• The DNR may consider other surface or subsurface conditions that may pose a threat to

health, safety, or the environment. Commercial waste management and transfer facilities must be designed and constructed so they protect public health, safety, and the environment, and do not allow movement of E&P wastes into the soil, groundwater, or surface waters. Sites must offer spill containment, including retaining walls around all aboveground storage tanks. Access to the sites must be controlled. Land treatment cells may not exceed five acres. With the exception of storm water retention ponds at land treatment facilities or sumps, pits may not be used for storage of E&P waste.

Table 2-3 Minimum Setbacks for Land Treatment of E&P Wastes

Type of Waste Minimum Setback

Distance (feet) Storage tank sludge with benzene = 113 mg/kg 1,000 Storage tank sludge with benzene >113 mg/kg or not tested 2,000 Natural gas plant processing waste solids with benzene = 3,198 mg/kg 2,000 Natural gas plant processing waste solids with benzene >3,198 mg/kg Not permitted for land

treatment Other E&P wastes 1,000

Commercial waste management and transfer facilities must develop a closure plan. Facility operators must also post a bond or letter of credit with the DNR to cover the adequate closure of the facility. In addition, operators of commercial E&P waste management and transfer facilities must provide evidence of financial responsibility to cover potential liability resulting from releases of E&P wastes from the facility. Commercial waste management and transfer facilities must develop an E&P waste management and operations plan that describes:

• The types and volumes of wastes that will be received,

• How they will be treated or disposed of,

• How they will be tested,

• A contingency plan,

• A monitoring and inspection program,

• A security plan,


• A community relations plan, and

• An environmental, health, and safety plan. In addition, commercial land treatment facilities must provide:

• A groundwater and facility monitoring plan,

• A plan to prevent or minimize air emissions,

• A plan to address the distribution of storage tank sludge between cells, and

• A reuse stockpile plan. At the discretion of the DNR, a commercial waste management or transfer facility may be required to install monitoring wells. If monitoring wells are installed, they must be sampled each quarter for pH, electrical conductivity, chloride, sodium, total dissolved solids, total suspended solids, total petroleum hydrocarbons, benzene, arsenic, barium, cadmium, chromium, copper, lead, mercury, molybdenum, nickel, selenium, silver, and zinc. Upon receiving a load of E&P waste, a commercial waste management or transfer facility must collect and analyze a sample of the waste for pH, electrical conductivity, chlorides, and, in some cases, NORM. This information is entered onto the shipping manifest accompanying the shipment. Commercial waste management and transfer facilities are allowed to use one or more of the following management options for E&P waste:

• Class II injection well (produced water)

• Class II injection well (slurry injection of solid wastes)

• Land treatment

• Phase separation

• Thermal desorption

• Salt cavern disposal

• Incineration

• Solidification (chemical fixation)


• Stabilization (chemical fixation)

• Other new technologies approved by the DNR on a case-by-case basis. The DNR rules contain detailed criteria for siting, design, construction, operation, monitoring, and closure for commercial land treatment facilities and salt caverns used for disposal of E&P wastes. These are summarized below.

2.3.1.5 Detailed Requirements for Land Treatment Facilities The seasonal high water table must be at least 36 inches below the soil surface. If this condition does not occur naturally, the operator may accomplish it through artificial drainage. Fluids collected in any drainage system should be monitored to provide early warning of possible migration of E&P waste contaminants. The concentration of constituents in groundwater aquifers may not exceed background concentrations. Free oil must be removed from all E&P waste before it can be applied to a cell. Natural gas plant processing waste solids that contain amounts of benzene equal to or less than 3,198 mg/kg may be applied to a land treatment cell without pretreatment, but batches of the waste that exceed 3,198 mg/kg must be pretreated to that level before they can be applied. Batches of storage tank sludge may be applied to cells if those cells meet the setback requirements described above. Produced water and gas plant waste fluids may not be applied to land treatment cells. E&P wastes may be applied to cells only during an application phase. This phase lasts for three months or until 15,000 bbl of waste per acre has been applied. The application phase is followed by a treatment phase lasting up to 24 months. In order to complete the treatment phase, cells must achieve the numerical performance limits shown in Table 2-4. Other numerical performance limits are set for closure of land treatment facilities, as shown in Table 2-4. Separate limits are used for the soils in the treatment zone and for runoff water.


Table 2-4 Numerical Limits for Land Treatment

Parameter

Completion of Treatment Phase

in a Cell

Closure Standards for Soils in the

Treatment Zone

Closure Standards for

Runoff Water pH range 6.5–9 6.5–9 6.5–9 Total petroleum hydrocarbons

3% by weight 3% 15 ppm

Benzene (TCLP procedure) N/A 0.5 ppm 0.5 ppm Electrical conductivity 10 mmhos/cm 10 mmhos/cm 2.0 mmhos/cm Sodium adsorption ratio 12 12 10 Total suspended solids N/A N/A 60 ppm Exchangeable sodium percentage

15% 15% N/A

Chlorides N/A N/A 500 ppm Arsenic 40 ppm 10 ppm 0.2 ppm Barium 100,000 ppm 100,000 ppm 10 ppm Cadmium 10 ppm 10 ppm 0.05 ppm Chromium 1,000 ppm 1,000 ppm 0.15 ppm Copper 1,500 ppm 1,500 ppm 1.3 ppm Lead 300 ppm 1,000 ppm 0.10 ppm Mercury 10 ppm 10 ppm 0.01 ppm Molybdenum 18 ppm 18 ppm N/A Nickel 420 ppm 420 ppm N/A Selenium 10 ppm 10 ppm 0.05 ppm Silver 200 ppm 200 ppm N/A Zinc 500 ppm 500 ppm 1.0 ppm

In addition to monitoring to determine compliance with the limits in Table 2-4, land treatment facilities must conduct several other types of monitoring programs, as indicated in Table 2-5.

2.3.1.6 Detailed Requirements for Salt Cavern Disposal Facilities The DNR modified Order 29-B in 2003 to add rules for disposal of E&P wastes in salt caverns. These are the most comprehensive requirements for salt cavern disposal anywhere in the United States and probably in the entire world. The rules apply to both commercial and non-commercial operators of salt cavern disposal facilities. Non-commercial operators would use a cavern to dispose of their own E&P wastes but would not accept wastes from other companies. Due to the complex and comprehensive set of requirements, it is anticipated that most disposal caverns facilities will be commercial facilities.


Table 2-5 Additional Monitoring Requirements for Land Treatment Facilities Prior to Receipt of Waste During Active Life of Facility

Parameter

Soil Ground Water

Underdrain

Soil

Ground Water

Underdrain

Sampling frequency

Once Once Once Quarterly Quarterly Quarterly

pH range X X X X X X Total petroleum hydrocarbons

X X X X X X

Benzene X X X X Electrical conductivity

X X X X X X

Sodium adsorption ratio

X

Total dissolved solids

X X X X

Total suspended solids

X X

Exchangeable sodium percentage

X X

Cation exchange capacity

X X

Chlorides X X X X X Arsenic X X X X Barium X X X X X X Cadmium X X X Chromium X X X X Copper X X X Lead X X X X X X Mercury X X X Molybdenum X X X Nickel X X X Selenium X X X Silver X X X Zinc X X X X X X Sodium X X X X X Reactive sulfides X X Calcium X Magnesium X Carbonate X Bicarbonate X Sulfate X


Cavern operators must obtain a permit from the DNR before disposing of E&P wastes. The permit application must include much detailed information, including, for example:

• Description of the site and planned facility, including maps of several types of surface and underground structures;

• An assessment of the geological properties of the salt stock and the overlying and

underlying layers;

• The location of the cavern in relation to adjacent caverns and the edge of the salt stock;

• An area of review analysis showing any wells, caverns, mines, or other underground structures within at least a one-half-mile radius of the cavern well;

• A technical description of the cavern and its well leading to the surface, including the

results of a sonar survey and a mechanical integrity test, and drawings showings construction details;

• A series of plans and procedures that document activities relating to:

o Cavern design, including spacing and setbacks; o Well construction, completion, and cementing; o Operating practices; o Safety and emergency management; o Monitoring and reporting; and o Closure and post-closure responsibilities.

Caverns and their associated surface facilities must be operated in a manner that avoids any releases of injected fluids into an underground source of drinking water or outside of the salt stock. They must also avoid any discharge of fluids, wastes, or other materials into drainage systems or surface water bodies. Any underground wells or structures identified during the area of review study that are not properly constructed or plugged and abandoned must be mitigated under the terms of a corrective action plan. No surface structures at a disposal cavern may be located within 500 feet of a residential, commercial, or public building unless the building owner waives the requirement. The outermost edge of the cavern may not be located less than 100 feet from the property boundary or less than 300 feet from the edge of the salt stock. There must be a separation of at least 200 feet between adjacent caverns or between a cavern and some other man-made structure within the salt stock. The DNR may waive the between-cavern separation distance when the applicant can demonstrate that it can safely operate adjacent caverns in a manner that allows them to coalesce and become a single cavern. Caverns may not be used for E&P waste disposal, if the cavern roof extends upward of the top of the salt stock. To minimize upward growth of cavern roofs, disposal caverns must place a layer of nonaqueous, low-density blanket material (typically oil) in the cavern before wastes can be added.


The maximum allowable injection pressure may not exceed a value calculated by multiplying the vertical depth by 0.8 psi. Caverns and the associated wells must be equipped with pressure gauges and continuous monitoring instruments. E&P wastes that are stored at the surface before injection into a cavern must be stored in aboveground tanks that are constructed on concrete pads and are surrounded by berms to collect any spilled materials. E&P wastes may not be stored at a cavern disposal facility for more than 14 days. Cavern operators must keep an accurate record of the volume of waste that is injected. Caverns may be filled with E&P waste up to 90% of their capacity. Any brine or other fluid displaced from a disposal cavern when E&P wastes are added must be managed in an environmentally protective manner. Caverns must be closed by removing the blanket material, plugging the well leading from the surface to the cavern with cement plugs, and installing a permanent surface marker noting that an E&P waste disposal cavern is located underneath the marker. Operators must review their post-closure plans annually and may be directed by the DNR to conduct monitoring of groundwater or surface subsidence and complete any necessary site restoration activities.

2.3.1.7 Recovery and Reuse of E&P Wastes The DNR encourages recovery of reusable materials through processing of E&P wastes. Commercial facilities may generate reusable materials as their only process or as part of other treatment processes. Companies must be permitted to undertake recovery or reusable materials. In order to obtain a permit, companies must provide information on the process they will use to recover the materials, the proposed uses of the reusable material, the proposed monitoring plan, and a reuse stockpile management plan. The recovered materials must meet the criteria in Table 2-6 before they can be reused. Recovered materials meeting the criteria may be used for daily cover in sanitary landfills when approved by the DEQ or for other construction fill purposes when approved on a case-by-case basis by the DNR.

2.3.1.8 Discharges to Surface Waters The national EPA regulations do not allow discharges of drilling waste or produced water from onshore or coastal wells to surface water bodies. The Louisiana regulations (under the DEQ) do allow for limited discharges of wastewater from drilling site reserve pits, ring levee borrow ditches, shale barges, drilling fluid dewatering systems, and abandoned or inactive oil field production pits that contain only nonhazardous oil field wastes. The treatment and discharge of water from offsite oil field waste disposal pits or pits containing waste other than nonhazardous oil field wastes are prohibited. Operators must first obtain the Louisiana equivalent of an NPDES permit. The permit contains numerical limits on pH, oil and grease, total suspended solids, chemical oxygen demand, chlorides, total chromium, and zinc.


Table 2-6 Testing Criteria for Reusable Material Parameter Solidification

Moisture content <50% or zero free moisture pH range 6.5–9.0 Electrical conductivity 8 mmhos/cm Sodium adsorption ratio 12 Exchangeable sodium percentage 15% Barium (reuse or stockpile at commercial facility) 100,000 ppm Barium (reuse at other locations) 40,000 ppm Benzene (Toxicity Characteristic Leaching Procedure) 0.5 mg/L

Criteria for Leachate

Total petroleum hydrocarbons 10 mg/L Chlorides 500 mg/L Arsenic 0.5 mg/L Barium 10 mg/L Cadmium 0.1 mg/L Chromium 0.5 mg/L Copper 0.5 mg/L Lead 0.5 mg/L Mercury 0.02 mg/L Molybdenum 0.5 mg/L Nickel 0.5 mg/L Selenium 0.1 mg/L Silver 0.5 mg/L Zinc 5.0 mg/L NORM Must meet DEQ standards

2.3.2 NORM Wastes

2.3.2.1 Definition and Description Naturally Occurring Radioactive Material(s) (NORM) is defined as any nuclide that is radioactive in its natural physical state (i.e., not man-made), but does not include source, by-product, or special nuclear material. The DEQ regulates the generation, management, decontamination, treatment, transfer, storage, and disposal of NORM and NORM waste with regard to both inactive and active sites and facilities involved in storage and/or cleaning of pipes and contaminated equipment. Produced water from crude oil and natural gas production is exempt from the requirements of these regulations. The recycling of NORM-contaminated equipment and the manufacturing, distribution, use, transportation, and disposal of materials used for building construction, industrial processes, metal casings, and abrasive cleaning are exempt from the requirements of these regulations.


The types of NORM waste or NORM-contaminated materials that are mostly likely to be found at an E&P site include pipes and other equipment containing radioactive scale, sludges, and soil contaminated by produced water spills. NORM, NORM waste, and NORM-contaminated material are exempt from the requirements of the regulations, if they contain, or are contaminated at, concentrations of 5 picocuries per gram or less of radium-226 or radium-228, above background, or 150 picocuries per gram of any other NORM radionuclide. Equipment that contains NORM is exempt from the requirements of the regulations, if the maximum radiation exposure level does not exceed 50 microroentgens per hour at any accessible point. Land is exempt from the requirements of the regulations, if it contains material at concentrations less than the limits specified below, in samples averaged over any 100 square meters, with no single noncomposited sample to exceed 60 picocuries per gram of soil:

• 5 picocuries per gram or less of radium-226 or radium-228, above background, averaged

over the first 15 centimeters, and 15 picocuries per gram above background averaged over each subsequent 15-centimeter-thick layer of soil; or

• 30 picocuries per gram or less of radium-226 or radium-228, averaged over

15-centimeter-depth increments, provided the total effective dose equivalent (from the contaminated land) to individual members of the public (continually present) does not exceed 0.1 rem (1 mSv) in a year.

2.3.2.2 Requirements Relevant to E&P Activities

The DEQ has issued a general license to mine, extract, receive, possess, own, use, store, and transfer NORM without regard to quantity. A general licensee is authorized to store NORM waste in a container for 90 days from the date of generation. After such time, the NORM waste must be transferred to an authorized facility for purposes of treatment, storage, or disposal, or a general licensee may submit a written NORM waste management plan to the DEQ. Surface equipment that has been removed from service and is not employed for its designated function must be decontaminated to the limits noted above or treated or disposed of within one year from the date the equipment was removed from service. This requirement does not apply to equipment that remains below ground and is associated with production wells or injection wells classified as having future utility. The general license does not authorize the manufacturing or distribution of products containing NORM, or the landfarming of NORM, or the transfer from one general licensee to another general licensee of NORM for purposes of decontamination or disposal. The general license does not authorize the cleaning of pipes and equipment in connection with a pipe yard, storage yard, or equipment yard. The DEQ issued a separate general license for pipe yards or storage yards or production equipment yards to receive, possess, process, and clean tubular goods or equipment that are contaminated with scale or residue but do not exceed 50 microroentgens per hour. Facilities covered under this type of general license must develop programs to screen radiation, ensure worker protection, control soil contamination, prevent release of NORM contamination beyond the site boundary, and clean up the site before releasing the area for unrestricted use. Facilities


that need to decontaminate tubular goods or equipment that exceed the 50-microroentgens-per-hour limit must obtain an individual license. NORM waste must be treated or disposed of in the following ways:

• Transfer of the wastes to a licensed NORM land disposal facility, • By alternate methods authorized by DEQ, or

• By transfer to an E&P waste commercial facility regulated by the DNR, if the facility can

meet treatment standards. Each shipment of NORM waste and NORM-contaminated equipment to a facility specifically licensed for treatment, decontamination, storage, or disposal shall be accompanied by a manifest. NORM and NORM waste must be kept in a container that is in good or safe condition. The container must be closed and sealed during storage, except when it is necessary to add or remove waste. Storage of new NORM waste by piles is prohibited. Once facilities, equipment, or sites exceed the level of contamination provided in the DEQ rules, they may not be released for unrestricted use until they have been decontaminated. 2.3.3 Solid Wastes Other than E&P Wastes

2.3.3.1 Hazardous Waste

A solid waste is a hazardous waste if it is not specifically excluded from regulation as a hazardous waste under DEQ regulations and:

• It exhibits any of the characteristics of hazardous waste (ignitability, corrosivity, reactivity, and toxicity),

• It is a chemical and/or process stream whose hazardous nature has been prescribed by

prior determination and is listed in the DEQ regulations, or

• It is a mixture of solid waste and one or more hazardous wastes. Determination of the characteristics is accomplished by (a) testing the waste according to the methods set forth in the Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW-846, or according to an equivalent method approved by the DEQ; or (b) applying knowledge of the hazard characteristic of the waste in light of the materials or the processes used. If the waste is determined to be hazardous, the generator should follow the details of the DEQ regulations for managing those specific wastes. The following wastes are exempt from full regulation as hazardous wastes: batteries, pesticides, thermostats, lamps, and antifreeze. The DEQ regulations closely follow the EPA guidelines and regulations. The


hazardous waste management rules are lengthy and complex and are not discussed any further here. Virtually all hazardous wastes generated at an E&P site will ultimately be managed offsite. A generator of hazardous waste must register with the DEQ to obtain a generator ID number. A generator who transports, or offers for transportation, hazardous waste for offsite treatment, storage, or disposal must prepare a manifest before transporting the waste offsite. Before transporting hazardous waste or offering hazardous waste for transportation offsite, a generator must package the waste correctly.

2.3.3.2 Industrial Solid Waste

Industrial solid waste is a solid waste generated by a manufacturing, industrial, or mining process, or which is contaminated by solid waste generated by such a process. This term does not include hazardous waste regulated under the DEQ hazardous waste regulations or under federal law, or waste that is subject to regulation under the DNR’s Statewide Order No. 29-B or by other agencies (i.e., E&P wastes). Generators of industrial solid waste may dispose of these wastes at a Type I facility licensed by the DEQ for disposing of industrial solid wastes. If the facility is also used for disposing of residential or commercial solid waste, it is also a Type II facility. In some cases, generators may choose to send industrial solid wastes to a Type I-A facility licensed by the DEQ. This is a facility used for processing industrial solid waste (e.g., a transfer station, incinerator waste-handling facility, shredder, baler, or compactor). If the facility is also used for processing residential or commercial solid waste, it is also a Type II-A facility. Generators of industrial solid waste must submit annual reports to DEQ listing the types and quantities of industrial solid waste they have disposed of offsite. The generator’s annual report should name the transporter(s) who removed the industrial solid waste from the generator’s site and the permitted solid waste processing or disposal facility or facilities that processed or disposed of the waste. Generators of industrial solid waste must maintain, for two years, all records concerning the types and quantities of industrial solid waste disposed of offsite. Prior to the initial transport of an industrial solid waste offsite, generators of industrial solid waste must submit a generator notification form, which includes analysis, analytical data, and/or process knowledge that confirm that the waste is not a characteristic or listed hazardous waste as defined by DEQ or EPA regulations, and obtain an industrial waste code number.

2.3.3.3 Residential Solid Waste

E&P sites may generate residential solid wastes, which are defined as any solid waste (including garbage, trash, and sludges from residential septic tanks and wastewater treatment facilities) derived from households (including single and multiple residences, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds, and day-use recreation areas. Residential solid wastes can be disposed of at a Type II facility, a facility used for disposing of residential or commercial solid waste. If the facility also is used for disposing of


industrial solid waste, it is also a Type I facility. In some cases, residential solid wastes may be sent to a Type II-A facility, a facility used for processing residential, infectious, or commercial solid waste (e.g., transfer station, incinerator waste-handling facility, refuse-derived fuel facility, shredder, baler, autoclave, or compactor). If the facility is also used for processing industrial solid waste, it is also a Type I-A facility.

2.3.4 Medical Wastes Most of Louisiana’s medical waste regulations are geared toward the health care industry. Some E&P operations may generate small volumes of medical waste. The DHH defines potentially infectious biomedical waste (PIBW) to include human pathological wastes, tissues, fluids, blood, tubes, vials, sharps, and bandages, among other materials. PIBW must be treated by incineration, steam sterilization, thermal inactivation, chemical disinfection, or irradiation. Following treatment, PIBW may be disposed of in a permitted solid waste landfill. Very small quantities of PIBW (less than 250 grams) may be disposed of in tightly sealed containers without needing disinfection. Small quantities of PIBW (less than 5 kilograms) may be transported by the generator to an approved facility. Larger quantities must be transported by a registered PIBW transporter to a permitted treatment facility. Only infectious waste from hospitals or clinics that has been properly packaged and identified and is certified noninfectious by the Department of Health and Hospitals may be deposited in Type I or II landfills.

Appendix 3: South Africa 3-1

APPENDIX 3: REPUBLIC OF SOUTH AFRICA South Africa is not a major oil and gas producer. However, exploration operations are ongoing. In this light, the following sections describe the general principles governing the waste management universe in South Africa. The regulatory history in this arena is relatively young. 3.1 AGENCIES WITH JURISDICTION OVER WASTE MANAGEMENT

OPERATIONS The National Environmental Management Act designates the Department of Environmental Affairs (DEAT) as the lead agency for the environment. The DEAT is entrusted with the task of enabling other national departments, provincial environmental departments, and municipalities to meet their executive obligations with respect to the environment, including pollution and waste management. The DEAT is the main custodian of the Environment Conservation Act (No. 73 of 1989). The Department of Water Affairs and Forestry (DWAF) is responsible for water quantity and quality aspects of pollution and waste management under the National Water Act (No. 36 of 1998) and exercises responsibilities pursuant to the Environment Conservation Act (No. 73 of 1989) with respect to hazardous waste and landfill permitting, including the development of applicable regulations, guidelines, and standards. The Department of Health and Welfare (DOH) establishes regulations and guidelines for hazardous substances as well as all medical wastes and treatment facilities, in consultation with DEAT. DOH regulates the medical industry within the context of environmental and health legislation. The major framework laws in South Africa that speak to waste materials and management activities are varied, fragmented, and rely on implementing regulations. Table 3-1 presents statutes that are relevant for waste management operations. Table 3-1 South African Framework Laws

Act Relevant Content Bill of Rights, Chapter Two of the South African Constitution (Act No. 108 of 1996)

States in Section 24 that everyone has the right to environmental protection through reasonable and other measures that prevent pollution, promote conservation, and secure ecologically sustainable development and use of natural resources, while promoting justifiable economic and social development.

National Environmental Management Act (No. 107 of 1998)

Provides for cooperative governance through principles for decision-making affecting the environment.

Environment Conservation Act (No. 74 of 1983)

Speaks to littering, waste management, and regulations, with an emphasis on land disposal sites.

National Water Act (No. 36 of 1998)

Addresses protection, use, development, and conservation of water resources. Water use includes disposing of waste in a manner, which may detrimentally affect a water resource.

Health Act (No. 63 of 1977) Used by DWAF to determine buffer zones of proposed waste disposal sites.


Under the aegis of the National Environmental Management Act (No. 107 of 1998), the DEAT has been engaged in an ongoing law reform process designed to develop and amend environmental legislation. In 1999, the Government of South Africa published the National Waste Management Strategies and Action Plans. In 2000, the DEAT published the White Paper on Integrated Pollution and Waste Management for South Africa — A Policy on Pollution Prevention, Waste Minimization, Impact Management, and Remediation:

• National Waste Management Strategies and Action Plans (1999) o National Waste Management Strategy o Capacity-building, Education, Awareness, and Communication o General Waste Collection o Implementing Instruments o Integrated Waste Management Planning o Waste Treatment and Disposal o Waste Information System o Waste Minimization and Recycling

• Other Waste Management Resources (2000)

o White Paper on Integrated Pollution and Waste Management for South Africa. DWAF has published several documents as part of its Waste Management Series, including:

• Minimum Requirements for the Handling, Classification, and Disposal of Hazardous Waste

• Minimum Requirements for Waste Disposal by Landfill

• Minimum Requirements for the Monitoring of Water Quality at Waste Management

Facilities. 3.2 WASTE CLASSIFICATION Waste is an undesirable or superfluous by-product, emission, or residue of any process or activity that has been discarded, accumulated, or been stored for the purpose of discarding or processing. Waste products may be gaseous, liquid, or solid, or any combination thereof. They may originate from domestic, commercial, or industrial activities, and include sewage sludge, radioactive waste, building rubble, as well as mining, metallurgical and power generation waste. Wastewater effluents are not defined as waste, because they are regulated and controlled under the National Water Act (No. 38 of 1998). Waste is divided into two classes pursuant to the concept of risk: general waste and hazardous waste. Within these two categories, waste is further classified by its source — domestic, commercial, or industrial. As noted above, there has been very little oil and gas exploration and production (E&P) activity in South Africa through 2003. Consequently, South Africa has not defined a specific waste category for E&P wastes, nor has it adopted separate E&P waste management regulations. In light of the precautionary principle, a waste must be regarded as a


hazardous waste when there is any doubt about the danger of the waste stream to humans or the environment. General waste refers to any waste that does not fall within the definition of hazardous waste. General waste is subdivided into paper, metals, glass, plastic, and organic and inert materials (including builders rubble). Due to its composition and characteristics, general waste does not pose a significant threat to public health or the environment, if managed properly. Hazardous waste is waste that has the potential, even in low concentrations, to have a significant adverse effect on public health or the environment because of its inherent toxicological, chemical, and physical characteristics. The DWAF minimum requirements documents describe four steps in the classification of a hazardous waste:

• Step 1: Identification of the waste or waste stream as probably hazardous.

• Step 2: Testing and analysis to determine the hazardous properties, characteristics, and components of a waste. This will confirm whether the waste is hazardous or not.

• Step 3: Classification and treatment in accordance with SABS Code 0228, The

Identification and Classification of Dangerous Substances and Goods. In the code, hazardous substances are assigned an identification number and divided into nine classes:

o Class 1: Explosives o Class 2: Gases o Class 3: Flammable Liquids o Class 4: Flammable Solids o Class 5: Oxidizing Substances and Organic Peroxides o Class 6: Toxic and Infectious Substances o Class 7: Radioactive Substances o Class 8: Corrosives o Class 9: Other Miscellaneous Substances.

• Step 4: Analysis and hazard rating of the waste or its residue to determine the hazard

rating and minimum requirements for disposal. The hazard rating provides an assessment of the risk posed by a hazardous substance in the waste, taking into account the amount of the substance, the so-called estimated environmental concentration (EEC), and the inherent toxicological hazard of the substance:

o Hazard Rating 1: Extreme Risk o Hazard Rating 2: High Risk o Hazard Rating 3: Moderate Risk o Hazard Rating 4: Low Risk.

Infectious hazardous waste includes not only medical or clinical waste, but also waste from biological research facilities and water analysis laboratories. Medical waste includes human tissue. The Gauteng Health Care Waste Management Regulations (Province of Gauteng), for example, divide health care waste into three categories:


• Health Care General Waste means the nonhazardous component of health care waste, and can include liquids, but excludes any health care waste generated from isolation wards.

• Health Care Risk Waste means waste capable of producing an infectious disease,

including any of the following: o Laboratory waste; o Human surgery specimens or tissue removed at surgery or autopsy; o Waste that contains recognizable fluid blood, fluid blood products, and containers

or equipment containing blood; o Waste containing discarded materials contaminated with excretion, exudates, or

secretions from humans or animals who or which are required to be isolated; o All waste generated in isolation wards; o Infectious liquids; o Sharps waste; o Chemical waste that consists of discarded solid, liquid, and gaseous chemicals,

including pharmaceutical waste and other hazardous waste from diagnostic and experimental work and from cleaning, housekeeping, and disinfecting procedures;

o Waste containing any radioactive material, or waste produced from patient treatment containing radioactive material; and

o Any waste, specimen, tissue, fluid, liquid, or sharp that resembles health care risk waste.

• Health Care General and Health Care Risk Liquid Waste include infectious and possibly

infectious waste, effluents that are chemically or possibly chemically hazardous, and radioactive waste.

3.3 WASTE MANAGEMENT REQUIREMENTS 3.3.1 General Waste General waste may be disposed of in a landfill that is registered, permitted, and operated in accordance with the minimum requirements under the Environment Conservation Act (No. 73 of 1989). General waste landfills include communal landfills, small landfills, medium landfills, and large landfills. If significant leachate is produced, the minimum requirements include a leachate collection system. Those general waste landfills are then designated as G:B+. In the absence of this requirement, they are identified as G:B–. 3.3.2 Hazardous Waste Once the analysis confirms that a waste does contain hazardous substances, the generator must register as a hazardous waste generator and determine the applicable minimum requirements. These may include pretreatment, destruction, venting, or disposal in accordance with all applicable laws. The minimum requirements for disposal are derived from the hazard rating. Certain wastes may not be landfilled, while others must be pretreated. The minimum requirements distinguish between two classes of hazardous waste landfills — H:H landfills and H:h landfills. An H:H landfill is more stringently designed, operated, and monitored than an H:h


landfill. An H:h landfill may only accept Hazard Ratings 3 and 4. A H:H landfill may accept all four hazard ratings. 3.3.3 Health Care Waste Infectious waste is classified as Hazard Rating 1 or Extreme Hazard Waste. Management methods include incineration at an approved facility or, in the absence of an available incineration facility, pretreatment by sterilization, direct irradiation, or microwaving prior to landfilling at an H:H or an H:h site. All medical waste containing human tissue must be incinerated. All infectious waste must be sterilized prior to landfilling or, in the alternative, must be incinerated at approved facilities. 3.3.4 Discharge Under the National Water Act (No. 36 of 1998), water use includes discharging waste or water containing waste into a water resource through a pipe, canal, sewer, sea outfall, or other conduit; disposing of waste in a manner that may detrimentally impact on a water resource; and disposing of water from any industrial or power generation process. Water use and impacts on water quality are regulated through a range of authorizations, which are directly managed by DWAF or in cooperation with other government departments. Standards for water quality and wastewater discharges are established by DWAF, and other ambient environmental quality standards are established by DEAT. Water use that may (potentially) have an impact on water quality must be licensed by DWAF in accordance with all applicable requirements under the National Water Act (No. 36 of 1998). The management of sewage sludge is regulated by the Water Services Act (No. 108 of 1997).

Appendix 4: Canada 4-1

APPENDIX 4: CANADA Canada is the world’s third largest producer of natural gas and the leading supplier to the United States. Canada ranks ninth in terms of the world’s oil production. In light of the recognition of the oil sands as a viable source, Canada’s reserves went from 7 to 180 billion barrels in 2003. Natural gas reserves remain at approximately 60 trillion cubic feet. Canada has established a mature industry in view of the onshore opportunities in the Western Canadian Sedimentary Basin, located along the eastern side of the Rocky Mountains. Roughly 80% of the Canadian oil and gas production occurs in the Province of Alberta. Other producing provinces are British Columbia and Saskatchewan. Small amounts of crude oil and gas are produced in the North West Territories, Yukon, Manitoba, and Ontario. The offshore industry has begun to develop, project-to-project, on the east coast of the country, but has not yet developed into any other region. Offshore production mainly occurs in Newfoundland and Nova Scotia; however, this should change over the next decade. For example, Devon Canada is planning the first offshore well to be drilled in the Arctic in 2005/06; and the Provinces of British Columbia and Quebec are working with the industry with respect to perspectives for projects in their waters. 4.1 AGENCIES WITH JURISDICTION OVER WASTE MANAGEMENT

OPERATIONS In Canada, various levels of government share the constitutional authority over environmental regulation and management. On the federal level, environmental protection responsibilities affecting waste management operations in the oil and gas exploration and production sector have been assigned to a myriad of federal agencies. The National Energy Board (NEB) is an independent federal agency that regulates several aspects of Canada’s energy industry. The NEB promotes safety, environmental protection, and economic efficiency in the Canadian public interest. The NEB is also responsible for the regulation of oil and gas operations in Canada’s offshore areas, except the Newfoundland and Nova Scotia offshore areas that are subject to the jurisdiction of petroleum boards created by accords between the federal and provincial governments. The Canada-Newfoundland Offshore Petroleum Board (C-NOPB) manages the petroleum resources in the Newfoundland offshore area on behalf of the government of Canada and the government of Newfoundland and Labrador. The Canada-Nova Scotia Offshore Petroleum Board (CNSOPB) is responsible for protection of the environment during all phases of offshore petroleum activities, from initial exploration to abandonment. Environment Canada has a mandated responsibility to provide advice on hazardous waste disposal to other federal departments and Crown agencies. As soon as the waste leaves the federal property, it is subject to the applicable provincial disposal regulations. These regulations may specify what landfills are licensed to receive particular wastes and what facilities are licensed to handle hazardous wastes. It is expected that in the near future federal hazardous waste regulations will be in place relative to the management of hazardous waste on federal


lands and to federal works and undertakings. The regulations will place limits on gaseous releases to the air, effluent releases, and leachate releases from solids. Transport Canada develops and implements programs and policies to protect the natural environment and to achieve a sustainable transportation system in Canada. Fisheries and Oceans Canada is responsible for marine safety and environmental protection. Health Canada is the federal department responsible for helping the people of Canada maintain and improve their health. In partnership with provincial and territorial governments, Health Canada provides national leadership to develop health policy, enforce health regulations, promote disease prevention, and enhance healthy living for all Canadians. Health Canada also works closely with other federal departments, agencies, and health stakeholders to reduce health and safety risks to Canadians. For example, in pursuance of the Canadian Energy Pipeline Association (CEPA), Health Canada works in partnership with Environment Canada to assess potentially toxic substances and to develop regulations to control toxic substances. The Canadian Nuclear Safety Commission (CNSC) regulates the transport of radioactive material. Indian and Northern Affairs Canada (INAC) is entrusted with two very broad mandates: Indian and Inuit Affairs and Northern Affairs. The Governor in Council is the governor general acting on the advice of the federal cabinet. Orders in council and minutes of council are signed by the governor general, giving legal force to cabinet decisions relating to a statutory authority or the royal prerogative. Table 4-1 presents the federal legal framework that may be relevant to waste management operations in the oil and gas sector. 4.2 WASTE CLASSIFICATION Definitions for wastes vary according to a myriad of potentially applicable legislation and implementing regulations. 4.2.1 Substances, Wastes, and Residues from Petroleum Drilling and Production

Operations (Offshore Waste Treatment Guidelines) The Offshore Waste Treatment Guidelines, published in August 2002 by the Canada-Newfoundland Offshore Petroleum Board (C-NOPB), the Canada-Nova Scotia Offshore Petroleum Board (CNSOPB), and the National Energy Board (NEB), offer definitions for wastes from petroleum drilling and production operations in Canada’s offshore areas; these are presented below. The guidelines supersede Offshore Waste Treatment Guidelines (September 1996), Offshore Waste Treatment Guidelines (January 1989), and Guidelines for the Use of Oil-Based Drilling Muds (November 1985).


Table 4-1 Federal Legal Framework Instruments Contents Agencies

The Offshore Waste Treatment Guidelines

Describe the minimum expectations for the treatment and disposal of wastes from oil and gas drilling and production operations carried out in Canada’s frontier areas, and outline the means by which operators are expected to demonstrate compliance with these expectations.

NEB, C-NOPB, CNSOPB

Guidelines Respecting the Selection of Chemicals To Be Used in Conjunction with Offshore Drilling & Production Activities on Frontier Lands

Provide a consistent framework for chemical section as part of the environmentally responsible management of chemicals used in offshore drilling and production activities.

NEB, C-NOPB, CNSOPB

Canada Oil and Gas Operations Act, Canada Oil and Gas Drilling Regulations, Canada Oil and Gas Production and Conservation Regulations

Promote safety, environmental protection, conservation of oil and gas resources, and joint production arrangements (apply to the Yukon and Northwest Territories or Sable Island, and specified submarine areas – inland waters not within a province, territorial seas, and the continental shelf of Canada).

INAC, NEB (designates Chief Safety Officer & Chief Conservation Officer)

Canada Environmental Protection Act (CEPA), Interprovincial Movement of Hazardous Waste Regulations, Regulations Respecting the Form and Content of an Application for a Permit for Disposal at Sea

Intended to protect human health and the environment, regulate the import, export, manufacturing, and use in Canada of certain substances, as well as prescribing certain obligations in the event that defined toxic substances are unlawfully discharged into the environment.

Canada Environment

Canada Water Act

Provides a framework for federal-provincial arrangements with respect to water resource management and water quality management, where national interests are involved.

Canada Environment


Instruments Contents Agencies Fisheries Act

Applies where fishing is carried out; Memorandum of Understanding between Fisheries and Oceans, and Environment Canada to outline the responsibilities of both departments for the administration and enforcement of the pollution prevention provisions.

Fisheries and Oceans Canada, Environment Canada (§§ 36–42)

Arctic Waters Pollution Prevention Act

Provides for the prevention of pollution of waters adjacent to the mainland and islands of the Canadian Arctic.

Transport Canada (shipping) and INAC (inshore)

Transportation of Dangerous Goods Act and Transportation of Dangerous Goods Regulations

Apply to all handling, offering for transport, and transporting of dangerous goods including hazardous wastes, by any means of transport (except pipelines and in bulk in vessels), whether or not the goods originate from or are destined for any place or places in Canada; under a 1986 Memorandum of Understanding, Environment Canada agreed to conduct inspections to determine compliance with the hazardous waste portion of the regulations and to process notices for the export and import of hazardous wastes.

Transport Canada

Canadian Guidelines for the Management of Naturally Occurring Radioactive Materials (NORM)

Developed to ensure adequate control of NORM encountered by affected industries, harmonize standards, and reduce jurisdictional gaps and overlap.

Health Canada

Produced water includes formation water, injection water, and process water that is extracted along with oil and gas during petroleum production. Drilling muds are fluids that are circulated in oil and gas wells to clean and condition the hole, lubricate the drill bit, and counterbalance formation pressure. Drilling muds typically use water, oil, or a synthetic fluid as the base fluid. A synthetic-based drilling mud (SBM) is defined as a drilling fluid whose continuous phase is composed of one or more fluids produced by the reaction of specific purified chemical feedstock, rather than through physical separation processes such as fractionation, distillation, and minor chemical reactions such as cracking and hydro-processing. SBM base fluids must have a total polycyclic aromatic hydrocarbon


concentration of less than 10 mg/kg, be relatively nontoxic in marine environments, and have the potential to biodegrade under aerobic conditions. Drill solids are particles that are generated by drilling into subsurface geological formations and are carried to the surface with drilling muds. Storage displacement water is water that is pumped into and out of oil storage chambers on certain types of production installations during oil production and off-loading operations. Bilge and ballast water is seawater that may seep or flow into the structure from various points in the offshore installation. Ballast water is used to maintain the stability of an offshore facility. Deck drainage is water that reaches the deck of offshore installations through precipitation, sea spray, or from routine operations such as washdown and fire drills. Produced sand originates from geological formations and is separated from formation fluids during oil and gas production. It may contain scale particles that are generated during the processing of those fluids. Well treatment fluids are fluids used in operations such as well workover, well stimulation, well completion, and formation fracturing. Cooling water typically contains chlorine and other biocide agents. Desalination brine is recovered from the production of potable water. Naturally occurring radioactive materials (NORM) are materials containing radioactive elements such as uranium, thorium, and potassium, and any of their decay products, such as radium and radon. These elements, which exist naturally, are present in the earth’s crust and within the tissues of all living beings at low levels, but pose no risk or hazard at these levels to human health or the environment. When oil and gas is processed to separate the oil, gas, and water, radioactive elements will precipitate in tubulars, production vessels, and other areas of the processing equipment exposed to fluids from the geological formation. This results in the formation of scales and sludges containing higher concentrations of radioactive elements, which may pose a risk to human health and require special handling and disposal practices. Other substances, wastes, and residues include sewage and food wastes, monoethylene glycol (MEG) (added to inhibit water formation in pipelines), sludges from oil-water separation systems, spent lubricants, plastic material, and excess or damaged supplies of chemicals. 4.2.2 Waste Material (Canada Oil and Gas Operations Act/Canada Oil and Gas Drilling

Regulations/Canada Oil and Gas Production and Conservation Regulations) Canada Oil and Gas Drilling Regulations

• Any refuse or garbage, or any other useless material generated during a drilling program and ancillary operations, but does not include drilling fluid and drill cuttings.


Canada Oil and Gas Production and Conservation Regulations • Any garbage, refuse, sewage, or waste well fluids or any other useless material that is

generated during a production operation or a production project. 4.2.3 Waste or Other Matter (CEPA) Waste or other matter means waste or other matter listed in Schedule 5, including:

• Dredged material.

• Ships, aircraft, platforms, or other structures from which all material that can create floating debris or other marine pollution has been removed to the maximum extent possible if, in the case of disposal, those substances would not pose a serious obstacle to fishing or navigation after being disposed of.

• Inert, inorganic geological matter.

• Uncontaminated organic matter of natural origin.

• Bulky substances that are primarily composed of iron, steel, concrete, or other similar

matter that does not have a significant adverse effect, other than a physical effect, on the sea or the seabed, if those substances:

o Are in locations at which the disposal or incineration at sea is the only practicable manner of disposing of or thermally destroying the substances; and

o In the case of disposal, would not pose a serious obstacle to fishing or navigation after being disposed of.

4.2.4 Waste (Canada Water Act/Arctic Waters Pollution Prevention Act and Regulations) Canada Water Act

• Any substance that, if added to any water, would degrade or alter or form part of a process of degradation or alteration of the quality of that water to an extent that is detrimental to their use by man or by any animal, fish, or plant that is useful to man.

• Any water that contains a substance in such a quantity or concentration, or that has been

so treated, processed, or changed, by heat or other means, from a natural state that it would, if added to any other water, degrade or alter or form part of a process of degradation or alteration of the quality of that water to the extent that is detrimental to their use by man or by any animal, fish, or plant that is useful to man.

Arctic Waters Pollution Prevention Act and Regulations

• Any substance that, if added to any water, would degrade or alter or form part of a process of degradation or alteration of the quality of that water to an extent that is detrimental to their use by man or by any animal, fish, or plant that is useful to man.


• Any water that contains a substance in such a quantity or concentration, or that has been so treated, processed, or changed, by heat or other means, from a natural state that it would, if added to any other water, degrade or alter or form part of a process of degradation or alteration of the quality of that water to the extent that is detrimental to their use by man or by any animal, fish, or plant that is useful to man.

• Without limiting the generality of the foregoing, includes anything that, for the purposes

of the Canada Water Act, is deemed to be waste.

• Subcategories: o Industrial waste means any waste produced by or arising from an industrial

operation. o Domestic waste means any waste other than industrial waste.

4.2.5 Deleterious Substance (Fisheries Act) Deleterious substance means:

• Any substance that, if added to any water, would degrade or alter or form part of a process of degradation or alteration of the quality of that water so that it is rendered or is likely to be rendered deleterious to fish or fish habitat or to the use by man of fish that frequent that water, or

• Any water that contains a substance in such quantity or concentration, or that has been so

treated, processed, or changed, by heat or other means, from a natural state that it would, if added to any other water, degrade or alter or form part of a process of degradation or alteration of the quality of that water so that it is rendered or is likely to be rendered deleterious to fish or fish habitat or to the use by man of fish that frequent that water.

It includes:

• Any substance or class of substances prescribed by regulation.

• Any water that contains any substance or class of substances in a quantity or concentration that is equal to or in excess of a quantity or concentration prescribed by regulation in respect of that substance or class of substances.

• Any water that has been subjected to a treatment, process, or change prescribed by

regulation. (Note that the Petroleum Refinery Liquid Effluent Limitations, which apply to refineries, list the following as deleterious: oil and grease, phenols, sulfide, ammonia nitrogen, total suspended matter, and any substance capable of altering the pH of liquid effluent or once-through cooling water.)


4.2.6 Toxic Substance (CEPA)

To be determined toxic under CEPA, substances must enter the environment in amounts that have or may have an immediate or long-term harmful effect on the environment or human health. CEPA takes a risk-based approach to decision-making that takes into account the entry of substances into the environment, exposure conditions, and inherent toxicity. 4.2.7. Hazardous Waste (CEPA/Interprovincial Movement of Hazardous Waste

Regulations) Hazardous waste means a product, substance, or organism that is:

• Included in any of dangerous goods Classes 2 to 6, 8, and 9 of the Transportation of Dangerous Goods Regulations:

o Class 2: Gases — compressed, deeply refrigerated, liquefied, or dissolved under pressure.

o Class 3: Flammable and combustible liquids. o Class 4: Flammable solids — substances liable to spontaneous combustion;

substances that on contact with water emit flammable gases. o Class 5: Oxidizing substances — organic peroxides. o Class 6: Poisonous (toxic) and infectious substances. o Class 8: Corrosives. o Class 9: Miscellaneous products, substances, or organisms considered by the

Governor-in-Council to be dangerous to life, health, property, or the environment when handled, offered for transport, or transported and prescribed to be included in this case.

• Intended for disposal or recycling, including storage prior to disposal or recycling.

• Is neither household in origin, nor returned directly to a manufacturer or supplier of the

product, substance, or organism for reprocessing, repackaging, or resale for any reason, including that the product, substance or organism is:

o Defective or otherwise not usable for its original purpose, or o In surplus quantities but still usable for its original purpose.

The Interprovincial Movement of Hazardous Waste Regulations apply to all transportation of hazardous waste that is:

• A solid in a quantity of 5 kg or more;

• Liquid in a quantity of 5 L or more; or

• A liquid or solid, or a mixture of liquids and solids, in a quantity of 500 grams or more that contains polychlorinated biphenyls in a concentration greater than 50 mg/kg.


4.2.8 Other Waste Categories Municipal solid waste is any waste managed by a municipality. The CCME has defined it as any material, product, or by-product for which the generator has no further use and which is discarded for management at waste management facilities. In addition to waste from urban or rural households, it may include waste from businesses, institutions, industries, and construction and demolition activities. Waste from industrial processes is not included is this category. Local municipal governments are responsible for municipal solid waste management.

Biomedical waste is waste generated by human health care facilities, medical research and teaching establishments, clinical testing or research laboratories, and facilities involved in the production or testing of vaccines. It contains or may contain pathogenic agents that may cause disease in humans exposed to the waste. Examples include human anatomical waste, animal anatomical waste, microbiology laboratory waste, waste sharps (needles and blades), blood, and body fluid waste. Infectious substance means a substance known or reasonably expected to contain viable microorganisms that are known or reasonably expected to cause disease in human beings or animals, and that meet certain risk group classification criteria and guidance under Transportation of Dangerous Goods (TDG) Act regulations. Examples of microorganisms are bacteria, viruses, rickettsia, parasites, fungi, or a recombinant hybrid or mutant of one of these. 4.3 WASTE MANAGEMENT REQUIREMENTS 4.3.1 Treatment and Disposal of Wastes from Petroleum Drilling and Production Areas

in Canada’s Offshore Areas (Offshore Waste Treatment Guidelines) The Offshore Waste Treatment Guidelines describe the minimum expectations of the C-NOPB, CNSOPB, and NEB for the treatment and disposal of wastes from oil and gas drilling and production operations conducted in Canada’s frontier areas. Table 4-2 summarizes the Offshore Waste Treatment Guidelines.


Table 4-2 Offshore Waste Treatment Guidelines (2002)

Waste Stream

Discharge Limitation Measurement

Frequency Analytical Method Reported Values Oil limit for existing facilities prior to publication of Guidelines: 40 mg/L (30-day weighted average); 60 mg/L (24-hour arithmetic average). Oil limit for new facilities and all existing facilities by 12/31/07: 30 mg/L (30-day weighted average; 60 mg/L (24 hour arithmetic average).

Measured every 12 hours and volume-weighted 30-day rolling average calculated daily.

Standard Methods for the Examination of Water and Wastewater (20th Edition), 5520 Oil and Grease, 5520 C Partition-Infrared Method and 5520 F Hydrocarbons.

Exceedance of either 30-day or 24-hour limit to be reported to Chief Conservation Officer within 24 hours of occurrence.

Produced water

Other: the composition of produced water should be analyzed for the following parameters and results submitted to Chief Conservation Officer:

• Aluminum, ammonia, antimony, arsenic, barium, boron, cadmium, chromium, cobalt, copper, iron, lead, magnesium, mercury, molybdenum, nickel, nitrogen, phosphorus, selenium, silver, strontium, sulfur, thorium, tin, uranium, vanadium, zinc: twice yearly via EPA Method 200.10 and EPA Method 245.1.

• Total petroleum hydrocarbons: twice yearly via mass spectrometry. • Aquatic toxicity: annually via sea urchin fertilization test method and at least two

other bioassay tests.

Drilling muds Water-based mud (WBM): no limits. Oil-based mud (OBM): no discharge. Synthetic-based mud (SBM): no discharge. Enhanced mineral-oil-based mud (EMOBM): no discharge. Operators should use WBM (preferred) or SBM – use of OBM and EMOBM approved only under exceptional circumstances – spent and excess WBM may be discharged onsite from offshore installations without treatment.

Drill solids When associated with WBM: no limits. When associated with OBM: no discharge. When associated with SMB or EMOBM: where reinjection (preferred) is not technically or economically feasible, solids may be discharged

Measured for oil on solids every 12 hours and a mass-weighted rolling 48-hour average calculated in units of grams oil per 100 grams solid.

Procedure for Field Testing Oil Based Drilling Muds.

Time series of raw and averaged data (oil on solids) to be reported to Chief Conservation Office in accordance with approved schedule. Exceedances to be reported to Chief Conservation Officer within 24 hours of occurrence.


Waste Stream

Discharge Limitation

Measurement Frequency Analytical Method Reported Values

subsequent to treatment with best available treatment technology, which at present believed to achieve 6.9 g/100 g or less oil on wet solids.

Storage displacement water

Oil limit for treated water: 15 mg/L or less.

Measured every 12 hours.


Exceedances to be reported to Chief Conservation Officer within 24 hours of occurrence.

Bilge and ballast water

Oil limit for treated water: 15 mg/L or less. Discharge in accordance with Regulation 21 of the International Convention for the Prevention of Pollution from Ships.



Deck drainage Oil limit for treated water: 15 mg/L or less.



Produced sand

Case-specific approval subject to concentration of oil and aromatic contents. Treatment to reduce oil concentration to lowest level practicable.

Overall volume to be reported to Chief Conservation Officer.

Well treatment fluids

Oil limit for treated fluids: 30 mg/L or less. Maybe directed to produced water discharge. No discharge of well

Case-specific.

Case-specific.

Time series of raw and averaged data from required analyses to be reported to Chief


Waste Stream

Discharge Limitation

Measurement Frequency Analytical Method Reported Values

treatment fluids containing diesel or other highly aromatic oils (they are to be recovered at site and recycled, or transferred to shore for disposal). Strongly acidic fluids to be neutralized to a pH of at least 5.0 prior to discharge.

Conservation Officer.

Cooling water

Case-specific restrictions on level of residual chlorine. Use of alternative biocide agents subject to approval.

Desalination brine

No limit and discharge without treatment.

Sewage and food

Macerate to 6 mm or less prior to discharge. Case-specific additional treatment.

Water for testing fire control systems

No limit and discharge without treatment.

NORM

Operators to work with appropriate board relative to available disposal options. For general guidance, see Canadian Guidelines for the Management of Naturally Occurring Radioactive Materials (NORM), Cat. H46-1/30-2000E, Health Canada, October 2000.

4.3.2 Waste Material and Produced and Process Waters (Canada Oil and Gas Drilling

Regulations/Canada Oil and Gas Production and Conservation Regulations) Canada Oil and Gas Drilling Regulations

• All waste material, drilling fluid, and drill cuttings generated at a drill site must be handled and disposed of in a manner that:

o Does not create a hazard to safety, health, or to the environment; and o Is approved by the Chief Conservation Officer or Chief Safety Officer.

• Any oil or gas produced during formation flow tests must be stored in suitable tanks or

flared in a manner approved by the Chief.

• Where an oil spill occurs, oil spill countermeasures of a chemical nature must not used unless, in the opinion of the Chief Conservation Officer or Chief Safety Officer, there is a severe threat to the safety of persons, property, or the natural environment.

• In respect to a well that is offshore:

o Any waste fuel, oil, or lubricant must be collected in a closed system that is designed for the purpose, and

o Any stored waste oil or oily material not burned at the drill site must be transported to shore in a suitable container and properly disposed of at the shore.


• All sewage, galley, and other domestic waste that might contribute to pollution must be disposed of in a manner approved by the Chief.

• Combustible trash must not be burned at a drill site except where precautions are taken to

ensure that the fire does not endanger personnel or the safety of the well.

• Any spent acid or excess acid must be disposed of in a manner approved by the Chief.

• In respect to a well that is offshore, all noncombustible trash, including glass, wire, scrap metal, and plastics, must be transported to a port and properly disposed of at that port.

Oil and Gas Production and Conservation Regulations • Handling of Waste Material and Oil: The operator of a production site shall ensure that

all waste material and oil that are produced or stored at the production site are handled and disposed of in a manner that does not create a hazard to the health or safety of a person or cause damage to the natural environment.

• Sewage Treatment: The operator of a production site shall collect, treat, and dispose of

all waste material produced at the site and shall do so in a manner that prevents a hazard to health, avoids the creation of a nuisance, and maintains the quality of the natural environment.

• Produced and Process Waters:

o No operator shall operate a system for the disposal of produced water at sea unless the system is designed and maintained to ensure that the average oil content of the water does not exceed any monthly average or maximum daily volume that is specified in a requirement of the production operations authorization that authorizes the operation in which the water is produced.

o No operator shall discharge process water unless the water discharged is, in quality, equal to or better than water that meets any contamination limits specified in a requirement of the production operations authorization that authorizes the operation in which the water is produced.

o The operator of a production installation shall institute appropriate sampling and analysis procedures to ensure that the quality of produced water and process water meets any quality specified in a requirement of the production operations authorization that authorizes operation in which the water is produced.

o No operator shall dispose of produced water to the land surface or into bodies of fresh water.

o No operator shall dispose of produced water from a well at an onshore production site by evaporation in unlined surface pits unless the water is evaporated:

At a location at which the nature of the soil is such that the contamination of ground water is prevented; and

In a quantity and for a period not exceeding those specified in a requirement of the production operations authorization that authorizes the production of the produced water.


o No operator shall carry out a scheme for the underground disposal of water produced from a well unless the operator submits an application for approval to the Chief Conservation Officer for an injection scheme that:

Avoids surface pollution, and Assists the pressure maintenance of a pool.

o The Chief Conservation Officer shall approve the scheme for the underground disposal wherein the Chief Conservation Officer is satisfied that the underground disposal will avoid surface pollution and assist in the pressure maintenance of the pool.

4.3.3 Controlling Pollution and Managing Wastes (CEPA) Protection of the Marine Environment from Land-based Sources of Pollution. CEPA provides the authority to issue nonregulatory objectives, guidelines, and codes of practice to help implement the National Programme of Action for the Protection of Marine Environment from Land-Based Activities. These provisions are intended to supplement authority that exists in other federal, provincial, territorial, and aboriginal government laws.

Disposal at Sea. CEPA implements the 1972 Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter (the London Convention) and the 1996 protocol to that convention. The provisions prohibit the disposal (and incineration) of wastes in oceans within Canadian jurisdiction and by Canadian ships in international waters, unless the disposal is conducted under a permit. This division does not apply to disposal resulting from offshore exploration and processing of seabed mineral resources, which are regulated under the Canada Oil and Gas Act.

• Consistent with the 1996 Protocol to the London Convention, CEPA takes a precautionary approach by listing, in Schedule 5, the wastes and other matter for which a permit for disposal at sea can be sought. In other words, only a few types of waste are eligible for disposal under CEPA 1999. Everything else is prohibited. The following can be considered for disposal at sea under a permit: dredged material; ships, aircraft, platforms, and other structures; inert, inorganic geological matter; uncontaminated organic matter of natural origin; and bulky substances that are primarily composed of iron, steel, or concrete. Other materials are not eligible for disposal at sea. The Governor in Council may make regulations limiting the quantity or concentration of a substance (such as mercury) contained in waste that is eligible for disposal.

• To receive an ocean disposal permit, an applicant must comply with the Waste

Assessment Framework in Schedule 6 of CEPA (below) that requires consideration of other disposal options (such as recycling) and means to prevent or reduce the generation of waste, such as cleaner production technologies. A permit for ocean disposal will be approved only if it is the environmentally preferable and practical option. An applicant must publish notice of the application in a newspaper that is circulated in the vicinity of the disposal area, and also pay a fee to process the permit request. In addition, when approved permits are published in the Canada Gazette, there is a 30-day period before any disposal under the permit can begin. During this time, any person may file a notice


of objection requesting a board of review. CEPA allows for emergency disposal to avert danger to human life or to a platform. CEPA also requires Canada Environment to monitor sites that are used for disposal.

• From the Waste Assessment Framework (Schedule 6 of CEPA):

o Acceptance of disposal at sea under certain circumstances does not remove the obligation to make further attempts to reduce the necessity for disposal.

o The initial stages in assessing alternatives to disposal at sea shall include an evaluation of the types, amounts, and relative hazard of waste or other matter generated; the details of the production process and sources of waste or other matter within that process; and the feasibility of the following waste reduction or prevention techniques: product reformulation, clean production technologies, process modification, input substitution, and onsite closed-loop recycling.

o If the required audit reveals that opportunities exist for waste prevention at source, an applicant shall formulate and implement a waste prevention strategy.

o For dredged material, the goal of waste management shall be to identify and control the sources of contamination. Until this objective is met, the problems of contaminated dredged material may be addressed by using disposal management techniques at sea or on land.

o Applications to dispose of waste or other matter shall demonstrate that appropriate consideration has been given to the following hierarchy of waste management options, which implies an order of increasing environmental impact: reuse, offsite recycling, destruction of hazardous constituents, treatment to reduce or remove the hazardous constituents, and disposal on land, into the air, and in water.

o A permit to dispose of waste or other matter shall be refused if opportunities exist to reuse, recycle, or treat the waste or other matter without undue risks to human health or the environment or disproportionate costs.

o A detailed description and characterization of the waste or other matter are an essential precondition for the consideration of alternatives and the basis for a decision as to whether the waste or other matter may be disposed of at sea. If the waste or other matter is so poorly characterized that proper assessment cannot be made of its potential impacts on human health and the environment, the waste or other matter shall not be disposed of at sea.

o Characterization of the waste or other matter and their constituents shall take into account: origin, total amount, form, and average composition; physical, chemical, biochemical, and biological properties; toxicity; physical, chemical, and biological persistence; and accumulation and biotransformation in biological materials or sediments.

o A National Action List shall be developed to provide a mechanism for screening candidate wastes or other matter and their constituents on the basis of their potential effects on human health and the marine environment. In selecting substances for consideration in the Action List, priority shall be given to toxic, persistent, and bioaccumulative substances from human sources (e.g., cadmium, mercury, organohalogens, petroleum hydrocarbons, and, whenever relevant, arsenic, lead, copper, zinc, beryllium, chromium, nickel, vanadium, organosilicon


compounds, cyanides, fluorides, and pesticides or their by-products other than organohalogens). An Action List can also be used as a trigger mechanism for further waste prevention consideration.

o The Action List shall specify an upper level and may also specify a lower level. The upper level shall be set so as to avoid, as much as reasonably possible, acute or chronic effects on human health or on sensitive marine organisms representative of the marine ecosystem. Application of the Action List will result in three possible categories of waste or other matter:

Waste or other matter that contain specified substances, or which cause biological responses, exceeding the relevant upper levels shall not be disposed of at sea, unless made acceptable for disposal through the use of management techniques or processes;

Wastes or other matter that contain specified substances, or which cause biological responses below the relevant lower levels, should be considered to be of little environmental concern in relation to disposal at sea; and

Wastes or other matter that contain specified substances, or which cause biological responses below the upper levels but above the lower levels, require more detailed assessment before their suitability for disposal can be determined.

o Information required to select a disposal site shall include: physical, chemical, and biological characteristics of the water column and the sea bed; location of amenities, values, and other uses of the sea in the area under consideration; assessment of the constituent fluxes associated with disposal in relation to existing fluxes of substances in the marine environment; and economic and operational feasibility.

o Assessment of potential effects shall lead to a concise statement of the expected consequences of the sea or land disposal options.

o The assessment for disposal shall, as appropriate, integrate information on waste characteristics, conditions at the proposed disposal site(s), fluxes, and proposed disposal techniques and specify the potential effects on human health, living resources, amenities, and other legitimate uses of the sea. It shall, where possible, define the nature, temporal and spatial scales, and duration of expected impacts based on reasonably conservative assumptions.

o An analysis of each disposal option shall be considered in light of a comparative assessment of the following concerns: human health risks, environmental costs, hazards (including accidents), economics, and exclusion of future uses. If this assessment reveals that adequate information is not available to determine the likely effects of the proposed disposal option, then this option shall not be considered further. In addition, if the interpretation of the comparative assessment shows the disposal option to be less preferable, a permit for disposal at sea shall not be given.

o Each assessment shall conclude with a statement supporting a decision to issue or refuse a permit for disposal at sea.

o Monitoring is used to verify that permit conditions are met (compliance monitoring) and that the assumptions made during the permit review and site


selection process were correct and sufficient to protect human health and the environment (field monitoring).

o A decision to issue a permit shall be made only if all impact evaluations are completed and, where reasonably possible, the monitoring requirements are determined. The provisions of the permit shall ensure to the extent practicable that environmental disturbance and detriment are minimized and that the benefits are maximized. Any permit issued shall contain: data and information specifying the types and sources of materials to be disposed of; the location of the disposal site; the method of disposal; and monitoring and reporting requirements.

o Disposal sites shall be reviewed at regular intervals. Review of monitoring results will indicate whether field programs need to be continued, revised, or terminated, and will contribute to informed decisions regarding the continuance, modification, or closure of disposal sites.

Control of Movement of Hazardous Waste and Hazardous Recyclable Material and of Prescribed Nonhazardous Waste for Final Disposal. CEPA allows Canada to meet its commitments under the Basel Convention on the Control of Transboundary Movement of Hazardous Wastes and their Disposal, the OECD Council Decision C(92)39 concerning the transfrontier movement of waste destined for recovery operations, and the Canada-U.S. Agreement Concerning the Transboundary Movement of Hazardous Waste.

• CEPA provides authority to establish a permit system for the import, export, and transit of hazardous wastes, hazardous recyclable materials, and prescribed nonhazardous wastes destined for final disposal. Canada Environment has the discretion to refuse the granting of a permit, in accordance with criteria set out in regulations, if it is believed that the waste or material will not be managed in a manner protective of human health and the environment. Authority is also provided to recover costs for the processing of permits.

• Moreover, Canada Environment may, with the approval of the Governor in Council,

prohibit or restrict the import, export, and transit of waste for the purposes of implementing international environmental agreements.

• CEPA also addresses the environmental aspects of interprovincial shipments of

hazardous wastes and recyclable materials under the Transportation of Dangerous Goods Regulations:

o Details about proposed imports, exports, and transits must be published in the Canada Gazette, on the Environmental Registry, or in any other manner deemed appropriate.

o The Interprovincial Movement of Hazardous Waste Regulations provide for manifest requirements.

• Finally, CEPA provides authority to require exporters to prepare and implement

reduction/phase-out plans for hazardous waste that is shipped abroad for final disposal. Government Operations and Federal and Aboriginal Land. Under Canada’s Constitution, provincial laws do not normally apply to the federal Crown. This means that provincial and


territorial regulations covering emissions, effluents, environmental emergencies, waste handling, and any other environmental matter do not, for the most part, cover federal government operations and land, including aboriginal land. The “federal house” includes federal departments, agencies, boards, commissions, federal Crown corporations, federal works and undertakings, and federal land, as well as aboriginal land.

• CEPA provides the authority to fill this regulatory gap so that the federal house is covered by the same type of environmental regulations as entities regulated by provinces.

• It allows Canada Environment to establish objectives, guidelines, and codes of practice

for the federal house. 4.3.4 Controlling Toxic Substances (CEPA) Substance Assessment – Existing Substances. Canada Environment is required to maintain the Domestic Substances List, a list of the approximately 23,000 substances currently in use in Canada.

• Substances on the Domestic Substances List will be assessed under one of the three following tracks: Priority Substances List; Categorization of the Domestic Substances List; and Review Decisions of other OECD countries, and Canadian Provinces and Territories.

• Following an assessment, ministers must propose one of the three following measures: take no further action; add the substance to the Priority Substances List, unless it is already on the list; or recommend that the substance be added to the List of Toxic Substances or, where applicable, propose it for virtual elimination.

Substance Assessment – New Substances. Substances that are not on the Domestic Substances List are considered to be new substances. These cannot be manufactured or imported until certain requirements have been met. Management of Toxic Substances. The 1995 federal Toxic Substances Management Policy sets out two tracks for the management of toxic substances: virtual elimination and life-cycle management. Preventive or Control Measures. Manufacture and import of new substances found to be toxic can be prohibited or subjected to conditions specified by the ministers. Interim Orders. CEPA authorizes Canada Environment to issue interim orders on a substance when immediate action is needed to deal with a significant danger to the environment or human health. Release of Toxic Substances. Individuals are obliged to report any releases of toxic substances that contravene a regulation. Export of Substances.

• Prohibited substances;


• Substances whose export is subject to an international agreement that requires the

notification or consent of the receiving country; and

• Restricted substances. 4.3.5 Depositing Waste in Water Water Act

• Except in quantities and under conditions prescribed with respect to waste disposal in the water quality management area in question, including the payment of any effluent discharge fee, no person shall deposit or permit the deposit of waste of any type in any waters composing a water quality management area designated pursuant to the Water Act, or in any place under any conditions where the waste or any other waste that results from the deposit of the waste may enter any such waters.

• The prohibition is not applicable with respect to a designated water quality management

area until a proclamation has been issued, declaring it to be applicable with respect to that area.

• Implementing regulations (to be made by Governor in Council on a recommendation by

the water quality management area agency, or an overriding joint federal-provincial recommendation):

o Quantities, if any, of waste of any type that may be deposited in the waters composing that area and the conditions under which any such waste may be deposited;

o Charges to be paid by any person to the agency incorporated or named in respect thereof — for treatment of waste by the agency at a waste treatment facility that is operated and maintained by it, and for analysis of waste samples by the agency — and the persons by whom those charges are payable and the time or times at which and the manner in which those charges shall be paid;

o Water quality standards for the waters composing that area; and o Effluent discharge fees, if any, to be paid by any person to the agency

incorporated or named in respect thereof for the deposit of waste in the waters composing that area and the persons by whom those fees are payable and the time or times at which and the manner in which those fees shall be paid.

Arctic Waters Pollution Prevention Act and Regulations

• Prohibition. Except as authorized by implementing regulations, no person or ship shall deposit or permit the deposit of waste of any type in the Arctic waters or in any place on the mainland or islands of the Canadian Arctic under any conditions where the waste or any other waste that results from the deposit of the waste may enter the Arctic waters.

• Scope of Application. This prohibition does not apply to the deposit of waste in waters that form part of a water quality management area designated pursuant to the Canada


Water Act, if the waste so deposited is of a type and quantity and is deposited under conditions authorized by regulations under that law relative to that water quality management area.

• Reporting Duties. Any person who has deposited waste in violation of the law, or carries

on any undertaking on the mainland or islands of the Canadian Arctic or in the Arctic waters that, by reason of any accident or other occurrence, is in danger of causing any deposit of waste, other than of a type, in a quantity, and under conditions prescribed by the regulations, must report the deposit of waste or the accident or other occurrence to a pollution prevention officer at such location and in such manner as may be prescribed by the Governor in Council.

• Regulations in General. The Governor in Council may make regulations for the purposes

of this section prescribing: o Type and quantity of waste, if any, that may be deposited by any person or ship in

the Arctic waters or in any place on the mainland or islands of the Canadian Arctic under any conditions wherein that waste or any other waste that results from the deposit of that waste may enter the Arctic waters; and

o Conditions under which any such waste may be so deposited.

• Arctic Waters Pollution Prevention Regulations. o Deposit of Domestic Waste: Any person may deposit or permit the deposit of

domestic waste, if the domestic waste is of a type and in a quantity and is deposited under conditions authorized by or under the Public Health Ordinance of the Northwest Territories or the Public Health Ordinance of the Yukon Territory, whichever is applicable.

o Deposit of Industrial Waste: Any person may deposit or permit the deposit of industrial waste, if the industrial waste is of a type and in a quantity and is deposited under conditions authorized by or under the Oil and Gas Production and Conservation Act, the Territorial Lands Act, or the Public Lands Grants Act, whichever is applicable.

o Report of Deposit of Waste or Danger thereof to a pollution prevention officer at Whitehorse in the Yukon Territory or at Yellowknife in the Northwest Territories by telecommunication or, where telecommunication is not available, by the fastest means available.

o Limits of Liability. In the case of an operation engaged in exploring for, developing, or exploiting oil and gas: $40 million.

Fisheries Act

• Prohibitions. o Throwing overboard ballast, coal ashes, stones, or other prejudicial or deleterious

substances in any river, harbor, or roadstead, or in any water where fishing is carried on.

o Depositing or permitting the deposit of a deleterious substance of any type in water frequented by fish or in any place under any conditions where the


deleterious substance or any other deleterious substance that results from the deposit of the deleterious substance may enter any such water, unless the deposits are authorized by regulations (Governor in Council) and ministerial directions, as applicable.

• Liability to Fishermen.

o Where, as a result of an unauthorized deposit, a deleterious substance enters water frequented by fish, the responsible are parties are jointly and severally liable for all causal loss of income incurred by any licensed commercial fisherman.

4.3.6 NORM Management The Canadian Guidelines for the Management of Naturally Occurring Radioactive Materials (NORM) (Cat. H46-1/30-2000E, Health Canada, October 2000) establish principles for the detection, classification, handling, and material management of NORM in Canada. They also include guidance for compliance with federal transportation regulations.

• NORM Standards. Table 4-3 presents the recommended values for the annual incremental effective dose to persons exposed to NORM as the result of work practice.

Table 4-3 Radiation Dose Limits

Affected Group

Annual Effective Dose Limit (mSv)

Five Year Cumulative Dose Limit (mSv)

Occupationally exposed workers

20 100

Incidentally exposed workers and members of the public

1 5

• NORM Material Management. NORM Derived Release Limits (DRLs) have been determined from the annual radiation dose limits. The guidelines recommend that NORM may be released with no radiological restriction when the associated dose is no more than 0.3 mSv in a year. Table 4-4 displays the unconditional DRLs for diffuse NORM sources. Table 4-5 shows the unconditional DRLs for discrete NORM sources. Table 4-6 presents surface contamination unconditional DRLs for discrete NORM sources.

• NORM Transport.

o Unrestricted NORM shipments: Material with activity less than or equal to 70 Bq/g; Material exempt under Nuclear Safety and Control Act; Material meeting unconditional DRLs.


o NORM shipments subject to the guidelines: Less than 70 Bq/g total specific activity and NORM quantities above

unconditional DRLs. o NORM shipments governed by federal transport regulations:

Material with greater than 70 Bq/g total specific activity. See Canadian Nuclear Safety Commission regulations and Internal Atomic

Energy Agency Safety Series regulations. o NORM surface contamination exclusions:

The non-fixed contamination when averaged over each 300 cm2 of all surfaces is less than 0.4 Bq/cm2 for beta and gamma emitters and low-toxicity alpha emitters, and is less than 0.04 Bq/cm2 for all other alpha emitters.

The object itself has an average specific activity less than 70 Bq/g. Table 4-4 Unconditional DRL for Diffuse NORM Sources NORM Radionuclide DRL Aqueous (Bq/L) DRL Solid (Bq/kg) DRL (Bq/m3)

Uranium-238 series (all progeny)

1 300 0.003

Uranium-238 (U-238, Th-234, Pa-234m, U-234)

10 10,000 0.05

Thorium-230

5 10,000 0.01

Radium 226 (in equilibrium with its progeny)

5 300 0.05

Lead-210 (in equilibrium with bismuth-210 and polonium-210)

1 300 0.05

Thorium-232 series (all progeny)

1 300 0.002

Thorium-232

1 10,000 0.006

Radium-228 (in equilibrium with actinium-228)

5 300 0.005

Thorium-238 (in equilibrium with its progeny)

1 300 0.003

Potassium-40

N/A 17,000 N/A


Table 4-5 Unconditional DRL for Discrete NORM Sources NORM Radionuclide Unconditional DRL (Bq/kg)

Uranium ore (in equilibrium with all progeny)

1,000

Uranium-238 (partitioned)

10,000

Thorium-230 (no progeny)

10,000

Radium-226 (in equilibrium with all progeny)

10,000

Lead-210 (in equilibrium with bismuth-210 and polonium-210)

10,000

Thorium-232 (in equilibrium with all progeny)

1,000

Radium-228 (in equilibrium with actinium-228)

100,000

Thorium-228 (in equilibrium with its short-lived progeny)

10,000

Potassium

1,000,000

Table 4-6 Surface Contamination Unconditional DRLs for Discrete NORM Sources

Property Limit Dose rate

0.5 µSv/h at 50 cm

Surface contamination

1 Bq/cm2 averaged over 100-cm2 area

4.3.7 Biomedical Waste Biomedical waste management must follow the minimum national standards and procedures for the regulation and management of biomedical waste across Canada outlined in the Canadian Council of Ministers of the Environment (CCME) Guidelines for the Management of Biomedical Wastes in Canada (1992) and, where applicable, the provincial regulations. For example, the Saskatchewan Biomedical Waste Management Guidelines address the handling of biomedical waste, which includes animal biomedical wastes, microbiology laboratory wastes, and wastes produced by the health biotechnology sector. The guidelines provide a classification system for biomedical waste and establish the procedures for storage, treatment, and disposal. The guidelines contained in the Management of Biomedical Waste in Ontario address the handling of biomedical waste, including waste from facilities involved in the production and testing of vaccines, such as animal waste and live or attenuated vaccines, and wastes produced by the health biotechnology sector. The guidelines establish the procedure for segregation, packaging, storage, transportation, treatment, and disposal of biomedical waste.


The Laboratory Biosafety Guidelines, published by the Medical Research Council of Canada (MRC), provide the requirements for solid and liquid biohazardous waste disposal, including the waste disposal equipment necessary for laboratory waste disposal systems at the four containment levels.

Appendix 5: Alberta 5-1

APPENDIX 5: PROVINCE OF ALBERTA The Province of Alberta, located where the Rocky Mountains meet the prairie, accounts for 80% of the total Canadian oil and gas production. The following sections describe how different types of wastes are regulated in Alberta, with a special emphasis on the wastes that are directly part of the exploration and production (E&P) process 5.1 AGENCIES WITH JURISDICTION OVER WASTE MANAGEMENT

OPERATIONS Provincial legislation places the responsibility for various aspects of waste management and regulation on two levels of government and different government departments and agencies, including the Alberta Energy and Utilities Board (EUB), Alberta Environment (AENV), Alberta Infrastructure, and municipal governments and regional health authorities. The Canadian Council of Ministers of the Environment (CCME) has issued national guidelines. At the provincial level, responsibility for the regulation of wastes in Alberta has been divided between the EUB and AENV since 1993. The EUB is responsible for the regulation of upstream oilfield wastes, while AENV regulates all other wastes generated in Alberta. On May 31, 2000, both agencies entered into a memorandum of understanding with respect to the harmonization of waste management regulation. The EUB, operating under the Alberta Energy and Utilities Board Act, is an independent, quasi-judicial agency of the Government of Alberta. The EUB is entrusted with the mission to ensure that the discovery, development, and delivery of Alberta’s energy resources and utilities services takes place in a manner that is fair, responsible, and in the public interest. Among other activities, the EUB regulates the management of oilfield wastes under the authority of the Oil and Gas Conservation Act and the Oil and Gas Conservation Regulation. EUB responsibilities include:

• Schemes for deep well injection, slurry fracture injection, and cavern disposal of wastes, including associated surface facilities for these activities on upstream petroleum sites.

• Oilfield waste transfer stations feeding solely to an oilfield waste management facility.

• All waste management activities occurring on oil or gas sites within a production system,

including one-time treatment and permanent waste management components.

• All waste management facilities established for recovery of crude oil or other processing of oilfield wastes (except stand-alone landfills and incinerators).

The details with respect to the management of oilfield wastes at the generator’s facility site, the transportation of oilfield wastes on Alberta’s public roads, and the treatment and disposal of oilfield wastes at waste management facilities are outlined in various EUB documents, including interim directives, information letters, guides, and (general) bulletins. The interim directive (ID) implements a new regulatory requirement, establishes guidelines, or exempts from existing


regulatory requirements. The information letter (IL) explains policy, regulatory requirements, or internal operating procedures. The guide offers detailed assistance for preparing applications, understanding information requirements, or complying with regulatory requirements. The (general) bulletin, a document of a temporary nature, does not contain EUB requirements, but informs the energy industry and the public of EUB activities, including consultations, new programs, electronic submissions of data, or new publications. Bulletins do not set out EUB requirements. The EUB has recently begun an initiative to review, streamline, update, and clarify EUB requirements contained in interim directives, informational letters, and guides. First, the EUB will issue only directives replacing interim directives, information letters, and guides. Second, the EUB has renamed general bulletins as bulletins. Relative to oilfield waste management activities, the EIB has issued the following documents:

• ID 96-3 and Guide 58: Oilfield Waste Management Requirements for the Upstream Petroleum Industry

• IL 96-13 and Guide 50: Drilling Waste Management

• IL 94-2 and Guide 51: Injection and Disposal Wells, Well Classifications, Logging, and

Testing Requirements

• ID 2001-9 and Guide 55: Storage Requirements for the Upstream Petroleum Industry

• ID 99-4: Deposition of Oilfield Waste into Landfills

• ID 2000-3: Harmonization of Waste Management

• ID 2000-4: An Update to the Requirements for the Appropriate Management of Oilfield Wastes

• ID 2001-4: Financial Security for Oilfield Waste Management Facilities

• IL 99-2: Use of Produced Sand in Road Construction

• IL 98-2: Suspension, Abandonment, Decontamination, and Surface Land Reclamation of

Upstream Oil and Gas Facilities

• IL 98-1: Coordination of Release Notification Requirements and Subsequent Regulatory Response

• GB 2000-19: A Summary of the 1998 and 1999 Annual Oilfield Waste Disposition

Reports

• GB 2001-18: A Summary of the 2000 Annual Oilfield Waste Disposition Reports

• GB 2002-10: A Summary of the 2001 Annual Oilfield Waste Disposition Reports


• GB 2003-06: List of EUB Approved Oilfield Waste Management Facilities

• IL 99-4: EUB Enforcement Process, Generic Enforcement Ladder, and Field Surveillance Enforcement Ladder (with clarification dated February 24, 2000)

• Guide 36: Drilling Rig Inspection Manual

• Guide 37: Service Rig Inspection Manual

• Guide 63: Oilfield Waste Management Facility Inspection Manual

• Guide 64: Facility Inspection Manual.

AENV is entrusted with protecting Alberta’s air, land, and water under the authority of the Environmental Protection and Enhancement Act and the Water Act. It establishes policies, legislation, plans, guidelines, and standards for environmental management and protection. AENV regulates non-oilfield waste generated in Alberta. AENV’s responsibilities include:

• All offsite and mobile incinerators and thermal treatment units.

• All offsite landfills and dedicated land treatment facilities.

• Surface facilities for deep well injection, slurry fracture injection, and cavern disposal of wastes within an AENV-approved non-oilfield plant.

• Compost facilities.

• Waste management or recycling facilities handling non-oilfield wastes/recyclables or

mixtures of non-oilfield and oilfield wastes/recyclables.

• Transfer stations other than those feeding solely to an oilfield waste management facility. Waste management activities regulated by AENV are subject to the following legislation and guidance documents:

• Environmental Protection and Enhancement Act (EPEA) (establishing the principles and legal requirements for waste management)

• Activities Designation Regulation (identifying those waste management activities that

require approval, registration, or notification)

• Waste Control Regulation (establishing the administrative procedures and technical criteria for waste and recyclables management, waste importation, manifesting, and financial security)


• Approvals and Registrations Procedure Regulation (outlining the requirements for approval and registration applications)

• Release Reporting Regulation

• Substance Release Regulation

• Alberta User Guide for Waste Managers (interpreting and detailing the regulatory

requirements applicable to AENV hazardous waste/recyclable management)

• Code of Practice for Landfills

• Code of Practice for Composting Facilities

• Code of Practice for Small Incinerators (draft)

• Code of Practice for Land Treatment and Disposal of Soil Containing Hydrocarbons (draft).

Alberta Infrastructure administers the federal Transportation of Dangerous Goods (TDG) Act and TDG regulations (containing requirements governing goods classification, packaging, and transportation). 5.2 WASTE CLASSIFICATION Waste has also been defined in the EPEA for purposes of specific contexts as any solid or liquid material or product or combination of solid or liquid material or product, including, but not limited to, rubbish, refuse, garbage, paper, packaging, containers, bottles, cans, manure, human or animal excrement, sewage or the whole or a part of an animal carcass, or the whole or part of any article, raw or processed material, or a vehicle or other machinery that is disposed of. In addition, waste is anything designated as such by regulation. Under the Waste Control Regulation, waste means any solid or liquid material or product or combination of them that is intended to be treated or disposed of or that is intended to be stored and then treated or disposed of, but does not include recyclables. For oilfield waste (EUB) and all other non-oilfield waste (AENV), the regulatory agencies prescribe parallel criteria relative to the characterization and classification of specific wastes, the properties to be measured, the analytical methods to be used, and the chemical parameters to be tested. 5.2.1 Oilfield Waste (EUB) From the EUB’s perspective, oilfield waste can only be generated on an upstream petroleum site that is licensed or approved by the EUB. Oilfield waste is defined as an unwanted substance or mixture of substances that results from the construction, operation, abandonment, or reclamation of a facility, well site, or pipeline, but does not include an unwanted substance or mixture of


substances from such a source that is received for storage, treatment, disposal, or recycling at a facility that is regulated by AENV. Drilling waste means the mud and cuttings generated from drilling a well. Oilfield waste falls into two subcategories:

• Non-Dangerous Oilfield Waste (non-DOW)

• Dangerous Oilfield Waste (DOW). EUB offers oilfield waste characterization and classification guidance (see Figure 1 below). The determination starts with the question of whether the waste stream is listed in Appendix 7.0 of EUB Guide 58.

• If yes: classification via Section 7.4 of Appendix 7.0 of EUB Guide 58 (Waste Management Table — see Attachment A to Appendix 5). Listed as DOW? Listed as non-DOW? Listed as “Testing Required”/“See Comments”? (For DOW properties and criteria, see Tables 5-1 and 5-2 below.)

o Examples. NORM, “unneutralized” acid solutions, wet-cell batteries, caustic solutions, and chemicals are classified as DOW. Produced water, construction and demolition materials, certain dry-cell batteries, and dry cement returns are classified as non-DOW. Contaminated debris and soil, pigging waste, and activated carbon require testing.

• If no or unclear: classification via the Alberta Guide for Waste Managers, published by

AENV.

• Certain small-volume oilfield waste is not considered dangerous if produced at any single site in an amount less than 5 kilograms per month if a solid, or 5 liters per month if a liquid and the total quantity accumulated does not exceed 5 kilograms or 5 liters at any one time.

• Oilfield wastes must not be mixed with any solid or liquid for the primary purpose of

diluting them.


Table 5-1 Properties of Dangerous Oilfield Waste (Table 4.1a of EUB Guide 58) Property Description

Flammability Waste has a flash point of less than 61oC. Waste ignites and propagates combustion in a test sample.

Spontaneous combustion potential Waste generates heat at a rate greater than it loses heat and reaches the auto-ignition temperature.

Water incompatibility Waste generates flammable or explosive gases in contact with water.

Oxidizing potential Waste contributes oxygen for combustion at a rate that is equal to or greater than that provided by ammonium persulphate, potassium perchlorate, or potassium bromate.

Toxicity Waste has an oral toxicity LD50 not greater than 5,000 mg/kg. Waste has a dermal toxicity LD50 not greater than 1,000 mg/kg. Waste has an inhalation toxicity LC50 not greater than 10,000 mg/m3 at normal atmospheric pressure.

Corrosivity Waste has a pH value less than 2.0 or greater than 12.5.

Polychlorinated biphenyl contents Waste contains polychlorinated biphenyls at a concentration equal to or greater than 50 mg/kg.

Leachate toxicity Waste is a liquid or a solid that passes a 9.5-mm mesh opening, or a friable solid that can be reduced by grinding in a mortar and pestle to a particular size that passes a 9.5-mm mesh opening, or a mixture of these, and:

• It contains at a concentration of 100 mg/L or higher any substance listed in Table 1 of the Schedule to the Alberta User Guide for Waste Managers;

• Its leachate contains any substance listed in Table 2 of the Schedule to the Alberta User Guide for Waste Managers, in excess of the concentrations listed in that table; or

• It contains any of the following substances in a concentration greater than 0.001 mg/L:

o hexachloro-dibenzo-p-dioxins o pentachloro-dibenzo-p-dioxins o tetrachloro-dibenzo-p-dioxins o hexachloro-dibenzofurans o pentachloro-dibenzofurans o tetrachloro-dibenzofurans.


Table 5-2 Criteria for Dangerous Oilfield Waste (Table 4.1b of EUB Guide 58) • Waste types listed in Table 3 of the Schedule to the Alberta User Guide for Waste Managers. • Commercial products or off-specification products listed in Part A of Table 4 of the Schedule to the Alberta User Guide for Waste Managers. • Commercial products or off-specification products listed in Part B of Table 4 of the Schedule to the Alberta User Guide for Waste Managers. • Wastes with any of the properties as per Table 4.1a of EUB Guide 58 (Properties of Dangerous Oilfield Wastes). • Certain dangerous oilfield waste containers.


Figure 1 Classification of Oilfield Waste (Figure 5.1 of EUB Guide 58)a

Notes:

a Classify container rinsate as per container waste or the rinse solvent, whichever is more stringent. For complete classification requirements, see Section 5.2, Tables 4.1a and 4.1b, and Section 5.3 for containers (all references are to EUB Guide 58).

* Refers to schedules listed at the back of the Alberta User Guide for Waste Managers. ** Not considered DOW if produced at a single site in volumes <5 kg or <5 L per month and does not exceed this amount at any

time when accumulated (does not apply to Part B of Table 4-listed wastes in the Alberta User Guide for Waste Managers).


5.2.2 Non-Oilfield Waste (AENV) Non-oilfield waste is further classified into nonhazardous or hazardous. In the Alberta Guide for Waste Managers, AENV offers four hazardous waste classification steps (below). In general, hazardous waste is defined by its properties and other criteria, subject to certain exclusions.

• Step 1: Is the material a waste?

• Step 2: Is the waste excluded? The following are not hazardous wastes under Schedule 2 of the Waste Control Regulation and the lists of wastes and items offered in Part 1 of the Alberta User Guide for Waste Managers: o Household waste in the possession of the householder or while “unsegregated” in a

municipal waste management system. o Agricultural waste. o Domestic sewage. o Waste regulated under the Atomic Energy Control Act (Canada). o Waste resulting from emergency spill cleanups, if the Director or an investigator has

authorized the handling of the cleanup debris. o Biomedical waste. o Certain small-volume hazardous waste produced in an amount less than 5 kilograms

per month if a solid or 5 liters per month if a liquid and the total quantity accumulated does not exceed 5 kilograms or 5 liters at any one time.

o Waste resulting from the treatment of hazardous waste where the treatment employs a method, technique, or process that represents acceptable industry practice.

• Step 3: Is the waste of a type listed in Table 3 of the Schedule to the Alberta User Guide

for Waste Managers? Is the waste a discarded commercial product listed in Table 4 of the Schedule to the Alberta User Guide for Waste Managers?

• Step 4: Does the waste meet the properties and criteria of Schedule 1 of the Waste

Control Regulation? o The properties include flammability, oxidizing potential, toxicity, corrosivity,

polychlorinated biphenyl concentration, and leachate toxicity. AENV has compiled the test methods for each property in the Alberta User Guide

for Waste Managers. o Certain enumerated waste types, commercial products, or off-specification products

and containers are explicitly identified as hazardous wastes: Waste types listed in Table 3 of the Schedule to the Alberta User Guide for Waste

Managers. Commercial products or off-specification products listed in Part A of Table 4 of

the Schedule to the Alberta User Guide for Waste Managers. A container, other than an empty container, that has an internal volume greater

than 5 liters and contains a substance listed in Part A of Table 4 of the Schedule to the Alberta User Guide for Waste Managers.


A number of containers, other than empty containers, that have an aggregate internal volume greater than 5 liters and contain a substance listed in Part A of Table 4 of the Schedule to the Alberta User Guide for Waste Managers.

Commercial products or off-specification products listed in Part B of Table 4 of the Schedule to the Alberta User Guide for Waste Managers.

An unrinsed empty container that has an internal volume greater than 5 liters and contained a substance listed in Part B of Table 4 of the Schedule to the Alberta User Guide for Waste Managers.

A number of unrinsed empty containers that have an aggregate internal volume greater than 5 liters and contained a substance listed in Part B of Table 4 of the Schedule to the Alberta User Guide for Waste Managers.

5.2.3 Other Waste Categories

• Municipal solid waste is any waste managed by a municipality. The CCME has defined it as any material, product, or by-product for which the generator has no further use and which is discarded for management at waste management facilities. In addition to waste from urban or rural households, it may include waste from businesses, institutions, industries, and construction and demolition activities. Waste from industrial processes is not included is this category. Local municipal governments are responsible for municipal solid waste management.

• Industrial waste generally refers to waste that is produced in industrial processing and

service activities.

• Biomedical waste is waste generated by human health care facilities, medical research and teaching establishments, clinical testing or research laboratories, and facilities involved in the production or testing of vaccines. It contains or may contain pathogenic agents that may cause diseases in humans exposed to the waste. Examples include human anatomical waste, animal anatomical waste, microbiology laboratory waste, waste sharps (needles and blades), blood, and body fluid waste.

5.3 WASTE MANAGEMENT REQUIREMENTS 5.3.1 Oilfield Waste

5.3.1.1 Manifesting and Tracking Generators, transporters, and receivers of oilfield waste in Alberta must comply with all applicable manifesting and tracking requirements. All dangerous and non-dangerous oilfield wastes must be included in oilfield disposition reports.


5.3.1.2 Oilfield Waste Management Facilities Oilfield waste management facility means a facility the operation of which is approved by the EUB, including, without limitation, a waste processing facility, a waste storage facility, a waste transfer station, a surface facility associated with a disposal well, a biodegradation facility, an oilfield landfill, a thermal treatment facility, and any other facility for the processing, treatment, storage, disposal, or recycling of oilfield waste. Oilfield waste facilities must comply with all applicable requirements governing siting, safety, waste characterization, environmental documentation, design and operation, site assessment, groundwater protection, recordkeeping, and closure.

5.3.1.3 Injection and Disposal Wells Alberta uses a system of classifying injection and disposal wells on the basis of injected or disposed fluid such that design, operating, and monitoring requirements are consistent with the type of the fluids injected. The following waste streams are prohibited from disposal by subsurface injection (except in exceptional circumstances): municipal and industrial sewage; surface runoff water that meets surface discharge criteria or can meet surface discharge criteria without cost-prohibitive treatment; lube oils and spent solvents; diesel invert drilling fluids; and wastes for which appropriate treatment technology exists. For those wastes, an alternative disposal method is required. General criteria governing waste fluids deemed suitable for deep well disposal include: pH between 4.5 and 12.5, non-halogenated organic fraction of less than 10% by mass, total halogenated organic compound concentration of less than 1,000 mg/kg, and PCB concentration of less than 50 mg/kg. Table 5-3 summarizes well classifications, cementing/casing requirements, logging requirements (initial), other tests and submissions, and operating parameters described in EUB Guide 51. Specific disposal well regulations are contained in the Oil and Gas Conservation Regulations relative to water disposal and application requirements. EUB Guide 58 covers operating practices and principles for certain surface facilities that receive upstream oilfield wastes prior to deep well injection.

5.3.1.4 Landfilling EUB Guide 58 outlines the minimum requirements for the design and operation of EUB-regulated oilfield landfills. It also identifies the types of AENV-regulated landfills that may accept oilfield waste. The EUB requirements are generally consistent with the AENV Waste Control Regulation and the AENV Code of Practice for Landfills. Oilfield landfill classes differ by the types of waste streams suitable for disposal:

• Class Ia and Ib landfills: solid oilfield waste, dangerous and non-dangerous.

• Class II landfills: only for non-dangerous solid oilfield waste.

• Class III landfills: for non-dangerous, chemically inert, and non-leachable solid oilfield waste.


Table 5-3 Summary of Requirements by Well Class (EUB Guide 51) Class 1a Class 1b Class II Class III Class IV

Well Classification Oilfield/industrial wastes X Produced water/specific wastes X Produced water/brine equivalent X Hydrocarbon/inert/sour gases X Steam/potable water X

Cementing/Casing Requirements

Hydraulic isolation host zone X X X X X Cement across usable groundwaters X X X X X Surface casing below usable groundwaters X

Initial Logging Requirements Cement top locator (when no returns) X X X X X Hydraulic isolation X X X X X Casing inspection – conversion X X X X X

Other Tests and Submissions Annulus pressure test – initial X X X X Daily annular monitoring X Daily injectivity monitoring X Hydraulic isolation logging – every 5 years X Annual formation pressure survey X Annual packer isolation test X X X X Well summary/completion schematic X X X X X Area of review (1.6-km radius) X X

Operating Parameters Wellhead pressure limitation X X X X Positive annular pressure X EUB Guide 58 states that dangerous oilfield waste shall only be deposited into an approved Class I oilfield landfill or an AENV-regulated landfill that is approved to accept hazardous waste. EUB Guide 58, ID 99-4 and ID 2000-4, also provide that the disposal of liquid oilfield waste into any landfill class is prohibited. Therefore, any oilfield waste received at any Class I, II, or III landfill must be solid. Oilfield wastes intended for direct landfilling must pass the paint filter test (that is, classified as a solid) prior to the addition of any amendments. Provided the material passes the above test, the subsequent addition of sorbent material required to facilitate solids handling and to manage any interstitial liquids that could shake out during the transportation of these wastes to the landfill is acceptable. All oilfield wastes that are directed into Class III landfills must be solid and inert. Inert waste is defined as any solid waste that upon disposal in a landfill is not reasonably expected to undergo physical, chemical, or biological changes to such an extent as to produce substances that may cause an adverse effect. Examples include demolition debris, concrete, asphalt, glass, cement returns, scrap metal, and dry timber or wood that has not been chemically treated. Oilfield wastes normally require extensive treatment prior to being rendered inert. Table 5-4 summarizes the current requirements for EUB-regulated and AENV-regulated landfill classes.


Table 5-4 Requirements for Oilfield and AENV-Regulated Landfill Classes (ID 1999-4)

Class Ia Class Ib Class II Class III EUB: solid dangerous and non-dangerous oilfield wastes

EUB: solid dangerous and non-dangerous oilfield wastes

EUB: solid non-dangerous oilfield waste only

EUB: solid inert waste only

AENV: liquid and solid hazardous and nonhazardous wastes

AENV: solid hazardous and nonhazardous wastes

AENV: solid nonhazardous wastes only

AENV: solid inert waste only

Two liners (of which at least one is synthetic)

One liner (engineered clay or synthetic)

One liner (engineered clay or synthetic; otherwise, conductivity requirements or alternative groundwater performance standards)

No liners required, but waste containment

Leak detection between the liners

Leachate collection and removal

Leachate collection and removal

Leachate collection and removal (otherwise, conductivity requirements or alternative groundwater performance standards)

Groundwater monitoring Groundwater monitoring Groundwater monitoring Groundwater monitoring, only if deemed necessary by EUB or AENV

Surface water run-on/ run-off control




Suitable hydrogeology

Suitable hydrogeology Suitable hydrogeology Suitable hydrogeology

Table 5-5 identifies the total petroleum hydrocarbon (TPH) and chloride criteria that non-dangerous oilfield waste must now meet to be acceptable for disposal into Class II landfills. Oilfield wastes contemplated include produced sands, drilling mud and cuttings, oily sludges, tank and treater bottoms, and flare pit material.

5.3.1.5 Discharge EUB Guide 58 does not address onshore discharge operations to surface water bodies. (In general, any discharge into a watercourse is subject to approval by AENV.) Offshore discharge regulations are not available, because Alberta is landlocked. EUB can, however, authorize discharges and applications onto land.


Table 5-5 Class II Landfill Acceptance Criteria for TPH and Chloride in Non-DOW (ID 1999-4)

Landfill Design Requirements Oilfield Waste Quality Leachate collection/removal engineered clay or synthetic liner

TPH: no limit Chloride: no limit

No leachate collection/removal engineered clay or synthetic liner

TPH: <30,000 mg/kg Chloride: <5,000 mg/kg

Natural clay liner

TPH: <20,000 mg/kg Chloride: <3,000 mg/kg

5.3.1.6 Storage EUB Guide 55 outlines the requirements for aboveground tanks, underground tanks, containers, lined earthen excavations, and bulk pads. Table 5-6 summarizes general storage requirements for these containment devices. Table 5-6 General Requirements for Containment Devices (EUB Guide 55)

Containment Device (Size)

Design & Construction

Secondary Containment

Leak Detection Weather Protection

Aboveground tank (1–5 m3)

Supplier specifica-tion; non-leaking hoses, fittings, and nozzles; spill control devices

Not required Monthly visual inspection

External weather-protective coating or made from a weather-resistant material

Aboveground open-topped nonmetallic tanks (<30 m3)

Supplier specifications

Not required Monthly visual inspection; integrity verified every five years

Not applicable

Single-walled aboveground tank (>5 m3)

Cathodic protection in corrosive environments; external coating for steel tanks and internal coating in corrosive environments; spill control devices

Graded contain-ment area; dike capacity 110% of tank or 100% of largest tank plus 10% of aggregate volume of more than one tank; impervious liner

Monthly visual inspection; sand over liner and leakage collection area

External weather-protective coating or made from a weather-resistant material

Double-walled aboveground tank (>5 m3)

Cathodic protection in corrosive environments; external coating for steel tanks and internal coating in corrosive environ-ments; spill control devices, including

Double walls with interstitial space

Monthly monitoring of interstitial space

External Weather-protective coating or made from a weather-resistant material


Containment Device (Size)

Design & Construction

Secondary Containment

Leak Detection Weather Protection

overfill protection Underground tank Integrity testing of

tank and pigging prior to servicing; external coating and cathodic protection for steel tanks; possible internal coating; spill control devices

Double walls with interstitial space

Monthly monitoring of interstitial space

Not applicable

Container or group of containers (≤1 m3 total)

Not applicable Not required Monthly visual inspection

Not required

Container or group of containers (>1 m3 total)

Compatibility between container and stored materials; segregated areas

Dike, curb, and/or collection tray with a capacity of 100% of largest container or 10% of aggregate volume, whichever is greater

Monthly visual inspection

Physical cover or protective coating

Lined earthen excavation

Specific to facility; spill control devices

Impervious liner Weeping tile; monitoring well; monthly monitoring

Specific to facility and material type

Bulk pad (solid material)

Specific to facility Impervious liner Specific to material type

Specific to facility and material type

Table 5-7 summarizes the general and facility-specific inspection, monitoring, and recordkeeping requirements for various containment devices under Guide 55. Table 5-7 Inspection, Monitoring, and Recordkeeping Requirements (EUB Guide 55)

General Aboveground Storage Tanks

Underground Storage Tanks

Container Storage Areas

Lined Earthen Excavations Bulk Pads

Inspection and Monitoring Field test retained surface waters prior to discharge for chloride (<500 ppm), pH (6–9), no visible sheen,

Monthly external visual inspection of tank and diked area Integrity verified every five years (if

Monthly interstitial space monitoring for double-wall tanks Integrity verified every

Monthly external visual inspection

Monthly monitoring of leak detection system (field test any collected liquids for pH, chloride, hydrocarbon

If storing materials that may generate leachate, see lined earthen excavations






no chemical contamination, landowner consent, no release to water

installed prior to 1996 and >5m3 or open-topped, nonmetallic with internal volume < 30m3) Monthly interstitial space monitoring for double-wall tanks unless equipped with continuous monitor Alternative inspection frequencies allowed as per API Standards 653, Section 4

three years (if single wall and installed prior to 1996) Monthly monitoring of monitoring wells associated with single-wall tanks with secondary containment; field test any liquid for pH, chloride, hydrocarbon odor, and visible oil sheen

odor, and visible sheen – if any problem encountered, send to lab for analysis) Annual lab sample from leak detection liquids for pH, electrical conductivity, major ions, oil and grease, and any other parameter, at EUB discretion

Recordkeeping Maintain inventory records for wastes and chemicals for 2 years Maintain groundwater monitoring records for 5 years Maintain alternative leak protection records for 5 years, but preferably for lifetime Maintain copies of all re-quired approvals, licenses, registrations,

Maintain tank inspection records/results for 5 years, but preferably for lifetime of tank Maintain corrosion monitoring records for 5 years, but preferably for lifetime of tank Document abnormal circumstances and corrective actions from monthly visual tank and dike inspections and retain for 5 years, but preferably for lifetime of tank

Maintain tank inspection records/results for 5 years, but preferably for lifetime of tank Maintain corrosion monitoring records for 5 years, but preferably for lifetime of tank Document abnormal circumstances and corrective actions from monthly interstitial monitoring of double-wall tanks and retain for 5 years, but

Document abnormal circumstances from monthly visual inspections and retain for 5 years

Maintain monitoring results (including field and lab analytical results) and any subsequent corrective actions from leak detection systems for 5 years EUB notification required if contamination found in leak detection system; report to include 1) parameters that changed, 2) investigative work conducted, and 3) remedial

If storing materials that may generate leachate see lined earthen excavations






and permits onsite or at the Field Center Maintain names of all persons conducting inspection and monitoring programs Maintain records of surface water discharges, including pre-release field study results and volume released

Document abnormal circumstances and corrective actions from monthly interstitial monitoring of double-wall tanks and retain for 5 years, but preferably for lifetime of tank

preferably for lifetime of tank Maintain monthly monitoring well results and any corrective actions from single-wall tanks with secondary containment

work proposed

5.3.1.7 Land Treatment Approval holders or licensees are not required to submit applications or information to the EUB for onsite, one-time land treatment operations occurring on active oil and gas sites. They must, however, document their activities and comply with the protocol for onsite land treatment of a single application of non-refined hydrocarbon contaminated soil or pit/sludge on an active oil and gas site, as outlined in EUB Guide 58:

• The waste material contains less than 2 ppm organic halogen.

• The land treatment site does not have a slope that exceeds 5%, and is at least 100 m away from any permanent body of water.

• The receiving soil (0–15 cm depth) does not exceed AENV Tier I Criteria for

Contaminated Soil Assessment and Remediation with respect to electrical conductivity, sodium adsorption ratio, metals, and pH (Tier I soil quality guidelines are generic numerical concentrations for all site conditions and land uses without defining actual risk):

o Electrical conductivity: 2 dS/m o Sodium adsorption ratio: 6 o Metals (all in mg/kg):

Arsenic: 10 Barium: 600 Beryllium: 5 Bromide (water soluble): 20


Boron: (hot water soluble): 2 Cadmium: 1 Chromium (VI): 5 Chromium (total): 100 Cobalt: 20 Copper: 80 Cyanide (water soluble): 0.5 Cyanide (total): 5 Fluoride (total): 200 Lead: 50 Mercury: 0.2 Molybdenum: 4 Nickel: 40 Selenium: 2 Sulfur (elemental): 500 Thallium: 1 Vanadium: 100 Zinc: 120

o pH: 6 to 8.5.

• The maximum depth of the treatment zone must be at least 1 m above the seasonal high water table. EUB recommends that the subsoil exhibit a hydraulic conductivity of 10-5 cm/sec or less.

• Available area of receiving soil will result in a maximum spread rate of 75 kg/m2, or a

waste-to-soil mix ratio of 1:4 by volume. (Contaminated materials in excess of this capacity must be dealt with by other treatment means.)

• After mixing the waste with the receiving soil, the treatment zone meets the following:

o Maximum metal concentration does not exceed AENV Tier I criteria; o Electrical conductivity does not exceed 4 dS/m; o Maximum hydrocarbon concentration does not exceed 2% by mass; o Sodium adsorption ratio does not exceed 6; and o pH is between 6.5 and 8.5.

• The maximum predicted time required to reduce the hydrocarbon concentration in the

treatment zone to less than 0.1% by mass does not exceed 5 years.

• Application of wastes does not occur during the period from October 15 to the next April 30, during rainfall periods, or at other times when the soil is saturated with water, ice-covered, snow-covered, or frozen.

5.3.1.8 Biodegradation

According to EUB Guide 58, biocell or biopile techniques refer to the processes in which oilfield wastes are biologically degraded in a contained or controlled environment (through placement in


an impermeable cell structure or piling on an impermeable liner). Approval holders or licensees are not required to submit applications or information to the EUB for onsite, one-time biocell or biopile treatment operations occurring on active oil and gas sites. They must, however, document their activities. Those seeking to construct permanent biocells and biopiles (for the purpose of biodegrading oilfield wastes generated at one or more facilities) on an existing EUB-approved oil and gas site must submit an application for approval to modify the facility. Biocells and biopiles used for one-time, onsite treatment of oilfield wastes must consist of a containment device and a leachate collection system. Permanent biocells and biopiles must consist of a primary containment device, a secondary containment system, a leachate collection system, a leak detection system, and a groundwater monitoring system. For all facilities, pre- and post-treatment analyses must be conducted with respect to pH, electrical conductivity, major soluble ions, total metals, hydrocarbon concentration, and extractable organic halogens. EUB ID 2000-4 clarifies that oilfield wastes, with the exception of suitable cellulose materials (e.g., trees and other vegetative material resulting from lease construction, decontamination, or decommissioning), must not be sent to compost facilities or managed by compost components at waste management facilities.

5.3.1.9 Roadspreading EUB Guide 58 allows the application of certain oily by-product materials to road surfaces when operations meet minimum requirements and criteria governing characterization, application depth, mixing, sampling, analysis, and regulatory approval:

• Oily by-product material may be applied to road surfaces if certain characterization criteria are met:

o No free water. o Oil shall be of a density of greater than 920 kg/m3. Material with less than 5%

residual hydrocarbon is unacceptable as road mix. o pH ≥6. o Total salts (calculated as loading limit):

Na ≤5,000 kg/ha; and Cl ≤7,000 kg/ha.

o Total metals (concentration in sample): Cd ≤3 mg/kg; Hg ≤0.8 mg/kg; Pb ≤375 mg/kg; Ni ≤150 mg/kg; Cu ≤150 mg/kg; and Zn ≤600 mg/kg.

o Material must not contain halogenated hydrocarbons, hazardous chemicals, refined or lube oils, drilling waste, flare pit sludges, or deleterious substances such as filters, rags, vegetation, or other debris, including significant volumes of contaminated agricultural soils.


• The maximum depth of application of material is limited to the smallest of the “Calculated Application Depths” determined for Na and Cl using the formula: depth (cm) (calculated) equals the quotient of (1) the loading rate for Na and/or Cl (kg/ha) multiplied by 104; and (2) the density of the sample (kg/m3) (laboratory) multiplied by the concentration Na and/or Cl (mg/kg) (laboratory).

• If the material to be used for road surfacing or dust suppression is a combination of two

or more product streams, each must be sampled and analyzed.

• Appropriate sample methods must be used to obtain a representative sample from each storage facility or container whose contents are to be used in the disposal project.

• Several analyses are required for the characterization of the oily by-product materials:

o 1:9 water soluble extract for pH, specific conductance, chloride, sodium; o Composition analysis (Dean Stark) for % water, % solids, % hydrocarbons; o Total metals (USEPA 3050 (SW 846)) for cadmium, mercury, lead, nickel,

copper, zinc; o Specific gravity (Standard Methods for the Examination of Water and Waste

Water, APHA, AWWA, WPCF, 16th Ed., Washington, 1985, Method 213 E) for density of oily by-products resembling sludges; and

o Specific gravity (American Society for Testing and Materials, Washington, “Standard Method for Specific Gravity of Soils,” Designation D 854–83) for density of granular oily by-products such as oil sands and silts.

5.3.1.10 Thermal Treatment

Thermal treatment facilities include small-batch feed incinerators, campsite incinerators, fixed thermal treatment facilities, and mobile thermal treatment units:

• Small-batch feed incinerators, which are not allowed to burn more than 10 tons of waste per month, and campsite incinerators operating at oil and gas sites do not require approval from EUB.

• All other fixed thermal treatment facilities, operating at oil and gas or oilfield waste

management facilities must be approved by EUB.

• Non-dangerous oilfield waste may be incinerated at AENV-regulated incinerators that are approved to incinerate nonhazardous or hazardous wastes. The incinerators must be approved to accept third-party waste.

• Dangerous oilfield waste may be incinerated at AENV-regulated incinerators that are

approved to incinerate hazardous wastes. The incinerators must also be approved to accept third-party waste.


• Mobile thermal treatment facilities may be used to manage oilfield wastes on EUB-approved or EUB-licensed sites, provided that the technology is notified and approved or registered.

5.3.1.11 Drilling Waste

EUB Guide 50 covers drilling waste management operations. Drilling waste disposal options include onsite, offsite, land treatment disposal, and alternative disposal methods:

• Onsite disposal is conducted on an area of land where the subsoil is used for the disposal of drilling waste.

o Mix-bury-cover (M-B-C) occurs when drilling waste solids (and sometimes fluids or the total waste) are stabilized by mixing with subsoil.

o Landspreading is the disposal method whereby the drilling waste is spread onsite and incorporated into the subsoil.

• Offsite disposal is conducted on an area of land where topsoil is used for the disposal of

drilling waste. This normally includes cultivated land and vegetated land, but can also include non-stripped portions of a well site or drilling waste storage area. Landowner approval is required for all offsite disposal operations, outside of the surface lease boundaries.

o Landspraying occurs when the waste is sprayed offsite onto topsoil and may or may not be incorporated. Landspraying is not intended for wastes resulting from the use of hydrocarbon-based mud systems.

o Pump-off occurs when drilling-waste clear liquids are applied offsite, normally onto vegetated land. Clear liquids are not normally incorporated into the topsoil.

o Landspraying while drilling occurs when drilling wastes from approved mud systems are sprayed offsite onto topsoils at low application rates. The application is conducted during the drilling operation. Mud systems presently approved for this method are limited to fresh water gel, gypsum water, and nitrate gypsum water.

• Land treatment disposal is a treatment and disposal method in which applications from

one waste site are made on a dedicated parcel of land. The land is managed in a manner that allows the soil system to degrade, transform, and assimilate the waste constituents. It is intended for hydrocarbon-based drilling wastes and wastes with a high salt content. The land treatment site (onsite or offsite) can be used only once.

• Alternative disposal methods are intended for disposals utilizing new or innovative

technology, or when new mud formulations or additives are used. The specific loading criteria, testing requirements, and information requirements prescribed by EUB with respect to each disposal method are presented in Table 5-8.


Table 5-8 Criteria and Requirements for Drilling Waste Disposal (EUB Guide 50) Loading Criteria

Disposal Method Pre-Application

Conditions Maximum Application

Rate Post-Application

Conditions Testing Requirements Information

Requirements ONSITE Mix-bury-cover (M-B-C)

Receiving soil: impermeable subsoil Site: water table or permeable material must be at least 1 m below soil and waste mixture Waste: must pass toxicity assessment if mud additives require testing, or if hydrocarbon was added to mud system

Chloride: <2,000 mg/kg in the subsoil and waste mix Hydrocarbon content: 0.1% on a dry weight basis in the subsoil and waste mix Subsoil and waste mixture must be at least 3 parts subsoil to 1 part waste A minimum of 1 m of clean subsoil must cover subsoil and waste mixture

Chloride: lifetime loading of 1,600 mg/kg per disposal site Nitrogen: lifetime loading of 400 kg per disposal site Trace elements (total lifetime loading limits): Boron: 10 kg Cadmium: 3 kg Chromium: 200 kg Copper: 400 kg Lead: 200 kg Nickel: 50 kg Vanadium: 200 kg Zinc: 600 kg

Solids: chloride, trace elements,* toxicity assessment,* hydrocarbon* Total waste: chloride, trace elements,* nitrogen,* toxicity assessment,* hydrocarbon*

Pre-sampling: verbal notification to public lands or forest district office 24 hours prior to sampling of waste Pre-disposal: written notification to public lands, forest district, or EUB area office 48 hours prior to disposal (use of Notification of Drilling Waste Disposal form)

ONSITE Landspreading

Receiving soil: subsoil must be suitable for incorporation; electrical conductivity ≤4 dS/m; sodium adsorption ratio ≤8 Waste: Must pass toxicity assessment if mud additives require testing, or if hydrocarbon was added to mud system

Trace elements (for any incorporation depth): Boron: 5 kg/ha Cadmium: 1.5 kg/ha Chromium: 100 kg/ha Copper: 200 kg/ha Lead: 100 kg/ha Nickel: 25 kg/ha Vanadium: 100 kg/ha Zinc: 300 kg/ha Analytes (with incorporation into <30 cm subsoil depth): Chloride: 800 kg/ha Sodium: 500 kg/ha Total nitrogen: 400 kg/ha Total dissolved solids: 3,500 kg/ha Hydrocarbon: <0.1% (using a subsoil density of 1,700 kg/m3) Analytes (with incorporation into >30 cm subsoil depth): Chloride: 1,200 kg/ha Sodium: 750 kg/ha Total nitrogen: 400 kg/ha Total dissolved solids: 5,000 kg/ha Hydrocarbon: <0.1% (using a subsoil density of 1,700 kg/m3)


Fluids: electrical conductivity, sodium adsorption ratio, chloride, nitrogen,* toxicity assessment* Solids: electrical conductivity, sodium adsorption ratio, chlorine, trace elements,* toxicity assessment,* hydrocarbon* Total waste: electrical conductivity, sodium adsorption ratio, chloride, nitrogen,* trace elements,* toxicity assessment,* hydrocarbon* Receiving soils: electrical conductivity, sodium adsorption ratio

Pre-sampling: verbal notification to public lands or forest district office 24 hours prior to sampling of waste Pre-disposal: written notification to public lands, forest district, or EUB area office 48 hours prior to disposal (use of Notification of Drilling Waste Disposal form)


Loading Criteria





Requirements Maximum rate of application ≤1,000 m3/ha or ≤10 cm Subsoil and waste mixture must equal 3 parts subsoil to 1 part waste

OFFSITE Landspraying

Receiving soil (topsoil): slope <5%; electrical conductivity ≤2 dS/m; sodium adsorption ratio ≤6 Waste: must pass toxicity assessment

Winter: ≤20 m3/ha, >200 m from water body; Summer: ≤40 m3/ha, >100 m from water body Solids on vegetated land ≤6 tons/ha Trace elements: Boron: 5 kg/ha Cadmium: 1.5 kg/ha Chromium: 100 kg/ha Copper: 200 kg/ha Lead: 100 kg/ha Nickel: 25 kg/ha Vanadium: 100 kg/ha Zinc: 300 kg/ha Analytes (topsoil): Chloride: 400 kg/ha Sodium: 250 kg/ha Total nitrogen: 200 kg/ha Total dissolved solids: 1,800 kg/ha Hydrocarbon: <0.5% incorporated to a depth less than 15 cm within 2 weeks of spraying


Fluids: electrical conductivity, sodium adsorption ratio, chloride, nitrogen,* toxicity assessment Solids: electrical conductivity, sodium adsorption ratio, chloride, trace elements,* toxicity assessment, hydrocarbon* Total waste: electrical conductivity, sodium adsorption ratio, chloride, nitrogen,* trace elements,* toxicity assessment, hydrocarbon* Receiving soils: electrical conductivity, sodium adsorption ratio

Pre-sampling: verbal notification to public lands or forest district office 24 hours prior to sampling of waste Pre-disposal: written notification to public lands, forest district, or EUB area office 48 hours prior to disposal (use of Notification of Drilling Waste Disposal form) Include map of application area with written notification

OFFSITE Pump-Off (clear liquids only)

Receiving soil (topsoil): electrical conductivity ≤2 dS/m; sodium adsorption ratio ≤ 6 Waste: clear liquids only; must pass toxicity assessment; pH 5.5 to 8.5

Analytes: Chloride: 400 kg/ha Sodium: 250 kg/ha Total nitrogen: 200 kg/ha Total dissolved solids: 1,800 kg/ha Hydrocarbon – there must be no visible hydrocarbons on clear liquids Maximum rate of application ≤1,000 m3/ha

Chloride: lifetime loading of 1,600 mg/kg per disposal site

Clear liquids: pH, electrical conductivity, sodium adsorption ratio, toxicity assessment, nitrogen,* chloride, dissolved hydrocarbon* Receiving soils: electrical conductivity, sodium adsorption ratio

Pre-sampling: verbal notification to public lands or forest district office 24 hours prior to sampling of waste Pre-disposal: written notification to public lands, forest district, or EUB area office 48 hours prior to disposal (use of Notification of Drilling Waste Disposal form) Include map of application area with written notification


Loading Criteria





Requirements OFFSITE Landspraying while drilling (LWD)

Receiving soil (topsoil): slope <5%; electrical conductivity ≤2 dS/m; sodium adsorption ratio ≤6 Waste: must be an approved mud system; no visible hydrocarbons

Winter: ≤20 m3/ha, >200 m from water body; Summer: ≤40 m3/ha, >100 m from water body Solids on vegetated land ≤6 tons/ha Total dissolved solids <1,800 kg/ha; sodium <250 kg/ha Drill cuttings – must be disposed by M-B-C or landspreading

Not applicable Source water*: electrical conductivity, sodium adsorption ratio Total waste: electrical conductivity, sodium adsorption ratio Receiving soils: electrical conductivity, sodium adsorption ratio

Pre-drilling: inform public lands, forest district, or EUB area office 48 hours prior to drilling Pre-disposal: noti-fication not required to public lands, forest district, or EUB area office unless disposal >48 hours after rig release Post disposal: written notification to public lands, forest district, or EUB area offices (use of Notification of Drilling Waste Disposal form) Include map of application area with written notification

ONSITE/ OFFSITE Land treatment

Receiving soil: If on subsoil: electrical conductivity ≤4 dS/m; sodium adsorption ratio ≤8 If on topsoil: electrical conductivity ≤2 dS/m; sodium adsorption ratio ≤ 6

If on Receiving subsoil: Chloride <800 kg/ha Sodium <500 kg/ha If on Receiving topsoil: Chloride <400 kg/ha Sodium <200 kg/ha Trace elements: Boron: 5 kg/ha Cadmium: 1.5 kg/ha Chromium: 100 kg/ha Copper: 200 kg/ha Lead: 100 kg/ha Nickel: 25 kg/ha Vanadium: 100 kg/ha Zinc: 300 kg/ha

Receiving soil: If on subsoil: electrical conductivity ≤4 dS/m; sodium adsorption ratio ≤8; hydrocarbon ≤0.1% If on topsoil: electrical conductivity ≤2 dS/m; sodium adsorption ratio ≤6; hydrocarbon ≤0.5%

Fluids: electrical conductivity, sodium adsorption ratio, chloride, hydrocarbon Solids: electrical conductivity, sodium adsorption ratio, trace elements,* hydrocarbon Total waste: electrical conductivity, sodium adsorption ratio, chloride, trace elements,* hydrocarbon Receiving soils: electrical conductivity, sodium adsorption ratio Closure soils: electrical conductivity, sodium adsorption ratio, hydrocarbon Soil monitoring: required to monitor progress

Pre-drilling: inform regulator 48 hours prior to drilling well Pre-disposal: detailed disposal plan must receive approval from regulator prior to disposal Post-disposal: notify regulator using Notification form following disposal Include map of application area with written notification


Loading Criteria





Requirements ONSITE/ OFFSITE Alternative disposal methods

Specific to disposal option




Pre-disposal: detailed plan must receive approval from regu-lator prior to disposal Post-disposal: notify regulator using Notification form following disposal

* Test not always required.

5.3.1.12 Naturally Occurring Radioactive Material (NORM) EUB Guide 58 identifies NORM as a dangerous oilfield waste exhibiting the common criterion of toxicity. In the absence of specific provincial requirements governing NORM management options, the EUB refers to a document produced by the Western Canadian NORM Committee, entitled, Guidelines for the Handling of Naturally Occurring Radioactive Materials (NORM) in Western Canada (August 1995). 5.3.2 Non-Oilfield Waste The AENV Waste Control Regulation addresses the management of hazardous waste, hazardous recyclables, nonhazardous waste, security, and general standards for landfills, compost facilities, and waste collection containers.

5.3.2.1 Hazardous Waste Hazardous waste regulations provide requirements for personal identification numbers, manifesting, and hazardous waste management facilities. A hazardous waste management facility means a facility for the collection, storage, treatment, or disposal of hazardous waste, but does not include an onsite facility. Hazardous landfill regulations enumerate the types of hazardous wastes eligible for disposal, along with threshold concentration values and properties. Liquid hazardous wastes must be disposed of in Class Ia landfills. Solid hazardous wastes must be disposed of in Class Ia or Class Ib landfills.

5.3.2.2 Nonhazardous Waste Waste must not be disposed of in any place other than a waste management facility authorized in accordance with the Environmental Protection and Enhancement Act and the Waste Control Regulation. This general prohibition does not apply to certain agricultural waste, earth, and certain waste used for reclamation and unlikely to undergo physical, chemical, or biological changes (e.g., demolition debris, concrete, asphalt, glass, ceramic materials, scrap metal, and dry timber or wood that has not been chemically treated). Those responsible for a Class II or Class III landfill/Class II or Class III compost facility must ensure that the landfill/compost


facility is sited, designed, constructed, operated, and reclaimed so as to meet as a minimum the requirements and standards of the Waste Control Regulation and the Code of Practice for Landfills/Code of Practice for Compost Facilities. 5.3.3 Municipal Solid Waste Alberta’s municipalities provide for a host of different waste management facilities. Table 5-9 displays the various types of municipal solid waste management facilities in the province. 5.3.4 Biomedical Waste Biomedical waste is not a hazardous waste under Schedule 2 of the Waste Control Regulation. A manifest is therefore not required when shipping biomedical waste within Alberta. Biomedical waste management must follow the minimum national standards and procedures for the regulation and management of biomedical waste across Canada outlined in the CCME Guidelines for the Management of Biomedical Wastes in Canada (1992) and, where applicable, the provincial regulations. For example, the Saskatchewan Biomedical Waste Management Guidelines address the handling of biomedical waste which includes animal biomedical wastes, microbiology laboratory wastes, and wastes produced by the health biotechnology sector. The guidelines provide a classification system for biomedical waste and establish the procedures for storage, treatment and disposal. The guidelines contained in The Management of Biomedical Waste in Ontario address the handling of biomedical waste, including waste from facilities involved in the production and testing of vaccines such as animal waste and live or attenuated vaccines, and wastes produced by the health biotechnology sector. The guidelines establish the procedure for segregation, packaging, storage, transportation, treatment and disposal of biomedical waste. The Laboratory Biosafety Guidelines, published by the Medical Research Council of Canada (MRC), provide the requirements for solid and liquid biohazardous waste disposal, including the waste disposal equipment necessary for laboratory waste disposal systems at the four containment levels.


Table 5-9 Types of Municipal Solid Waste Management Facilities in Alberta (1995) Type of Municipal Solid Waste

Management Facility

Definition Sanitary landfill Waste management facility where waste material is

placed in trenches or on land, compacted by mechanical equipment, and covered with earth.

Regional landfill Sanitary landfill serving more than one community. One or more waste transfer stations may be associated with it.

Modified sanitary landfill Waste management facility that, by reason of its location and intended purpose, is subject to less stringent operational requirements than a sanitary landfill.

Dry waste site Waste management facility restricted to non-offensive classes of waste such as construction or demolition rubble.

Waste sorting/processing station Waste transfer station where waste is compacted, shredded, ground, processed, or sorted.

Waste storage station A facility that has been established to store one or more specific materials having intended uses.

Waste transfer station Specifically designated drop-off depots from which waste is collected and transported to the regional landfill.

Waste-to-energy incinerator A facility designated for municipal waste having state-of-the-art combustion and waste heat recovery.


ATTACHMENT A TO APPENDIX 5: EUB GUIDE 58, APPENDIX 7, SECTION 7.4 WASTE MANAGEMENT TABLE

• It is the generator’s responsibility to ensure that wastes are treated and disposed of properly. This table is based on wastes produced through the use of standard industry practices. If unusual properties are suspected to exist or the characteristics are uncertain, the general characterization method outlined in Section 6.2, Procedures for Classifying Waste, must be used.

• This table contains treatment and disposal information. Other issues such as worker

safety, material handling, and storage should also be considered. References for these areas include the Canadian Association of Petroleum Producers’ (CAPP) Production Waste Management Handbook, the Workplace Hazardous Materials Information System, and the TDG Act and regulations. All applicable TDG requirements must be met.

• The use of the “Acceptable Practices” column does not result in the reclassification of a

Dangerous Oilfield Waste or a waste indicated as “Testing Required” to a Non-Dangerous Oilfield Waste.

• Where classification of a waste is unclear, refer to AEP’s (AENV’s) Alberta User Guide

for Waste Managers, for further information.

• DOW = Dangerous Oilfield Waste.

• N-DOW = Non-Dangerous Oilfield Waste. Waste Management Table

EUB Waste Name [Waste Code]

Oilfield Class

Common Transport Class

Common Criteria

Common/Acceptable Practices Comments

Absorbents [OILABS]

Testing Required

Dependent on specific waste characteristics; consult TDG regulations

Flash point, leachate

Reuse via laundering/ dry-cleaning Remove entrained liquids and landfill at an approved Class Ia, Ib, or II landfill, depending on specific characteristics Thermal treatment

Normally not a DOW (depending on flash point or ignitability or leachate); if BTEX >1000 mg/kg, it cannot be landfilled

Acid solutions (unneutralized) [ACID]

DOW Use classification according to parent product

Corrosivity, heavy metals, flash point (if hydrocarbon present)

Adjust pH prior to disposal (if possible) Recover any hydrocarbons prior to disposal

See EUB Guide 51 for injection well requirements



Oilfield Class


Common Criteria


Inject down EUB Class Ia disposal well (pH 4.5–12.5) Inject down EUB Class Ib disposal well (pH 6.0–9.0) (if heavy metal content meets criteria outlined in EUB Guide 51) Physical/ chemical treatment

Activated carbon [ACTCRB]

Testing Required

Class 4.2 UN1362 N-DOW not TDG regulated


DOW: Reuse/ regenerate Thermal treatment N-DOW: Reuse/ regenerate Co-dispose (amendment) with soil sterilant contaminated materials Landfill at an approved Class Ia, Ib, or II landfill, depending on specific characteristics

This waste may be DOW, depending on leachate characteristics; if BTEX >1000 mg/kg, it cannot be landfilled

Asbestos [ASBEST]

See Comments

Waste White Asbestos, Class 9.1, UN2590 Waste Blue or Brown Asbestos, Class 9.1, UN2212

Toxic airborne fibers

Wet to reduce airborne dispersal and double bag Landfill at an approved Class Ia, Ib, or II landfill (must be covered immediately upon disposal)

See AEP’s Guidelines for the Disposal of Asbestos Waste, August 1989

Batteries (wet and dry cell) [BATT]

Wet Cell: DOW Dry Cell: N-DOW (unless containing KOH)

Wet cell – Class 8 (9.2), UN2794 – acid, UN2795 – alkali Dry cell – not TDG regulated (unless KOH) (Ni-Cd)

Corrosivity, leachate (heavy metals)

Recycle via battery recycler Remove liquids (wet batteries) and neutralize Landfill containers at an approved Class Ia, Ib, or II landfill

Alkaline batteries may be disposed of as per “Garbage – Domestic Waste”



Oilfield Class


Common Criteria


(depending on battery type)

Boiler blowdown water [BLBDWT]

See Comments

Not TDG regulated (unless contaminated with a DOW)

DOW: Reuse Inject down EUB Class Ia or Ib disposal well (depending on heavy metals) N-DOW: Reuse Inject down EUB Class Ia or Ib disposal well Surface discharge (must conform with discharge criteria outlined in Section 5.2.2 of EUB Guide 55 and be cooled to below 50oC prior to discharge)

Normally not a DOW (unless containing Cr, V, or other additives) See EUB Guide 51 for injection well requirements

Catalyst (non-sulfur) [CATNS]

Testing Required

Dependent on specific waste characteristics, consult TDG regulations

Leachate, pyrophoric characteristics

DOW: Reuse/ regenerate Containerize and landfill at an approved Class Ia or Ib landfill N-DOW: Reuse/ regenerate Containerize and landfill at an approved Class Ia, Ib, or II landfill, depending on specific characteristics

This waste may be DOW depending on leachate characteristics; if BTEX >1000 mg/kg, it cannot be landfilled

Catalyst (sulfur) [CATSU]

Testing Required


Leachate, corrosivity, pyrophoric characteristics

Reuse/ regenerate Containerize and landfill at an approved Class Ia, Ib, or II landfill, depending on specific characteristics (add lime as per AEP guidelines)

This waste may be DOW, depending on leachate characteristics; if BTEX >1000 mg/kg, it cannot be landfilled See AEP’s Guidelines for the Disposal of Sulphur Containing Solid Wastes, March 1983



Oilfield Class


Common Criteria


Caustic solutions (unneutralized, spent) [CAUS]

DOW Use classification according to parent product

Corrosivity Adjust pH prior to disposal (if possible) Inject down EUB Class Ia disposal well (pH 4.5–12.5) Inject down EUB Class Ib disposal well (pH 6.0–9.0) Physical/chemical treatment

May be Waste Type 203 (if used to clean heat exchangers that possess lead-containing materials [i.e., solder, adhesives]) See EUB Guide 51 for injection well requirements

Cement (returns dry) [Cement]

N-DOW Not TDG regulated

Crush material and bury on lease with at least 1 meter of cover Landfill at an approved Class Ia, Ib, II, or III landfill Incorporate material into gravel onsite or on entrance road

Chemicals (inorganic) [INOCHM]

DOW Dependent on specific waste characteristics; consult TDG regulations

Dangerous when wet; oxidizer, toxicity, corrosivity, leachate

Disposal practice will vary with specific chemical (consideration of compatibility and solubility) Reuse/recycle when possible Contact chemical waste exchange Physical/ chemical treatment

Chemicals (organic) [ORGCHM]


Flash point, oxidizer, toxicity, corrosivity, leachate

Disposal practice will vary with specific chemical Reuse/recycle when possible Contact chemical waste exchange Physical/chemical treatment



Oilfield Class


Common Criteria


Thermal treatment

Construction and demolition material [CONMAT]

See Comments


DOW: Decontaminate and reuse Landfill at an approved Class Ia or Ib landfill N-DOW: Reuse Landfill at an approved Class Ia, Ib, II, or III landfill

Normally not a DOW (unless contaminated with a DOW)

Contaminated debris and soil (chemical/solvent) [SOILCH]

Testing Required

Dependent on specific characteristics; consult TDG regulations

Flash point, leachate, toxicity

Disposal/treatment based on specific parameters of waste Thermal treatment Physical/chemical treatment Biodegradation Landfill at an approved Class Ia, Ib, or II landfill, depending on specific characteristics

Contaminated debris and soil (crude oil/ condensate) [SOILCO]

See Comments

Class 4.1 UN 3175


Biodegradation onsite (or offsite at an approved facility) Send to an approved oilfield waste processing facility for hydrocarbon recovery Thermal treatment

Normally not a DOW (depending on flash point and BTEX content)

Contaminated debris and soil (mercury/metals) [SOILHM]

Testing Required


Leachate (heavy metals), toxicity

Physical/chemical treatment Landfill at an approved Class Ia, Ib, or II landfill, depending on specific characteristics (Hg:



Oilfield Class


Common Criteria


20 mg/kg – waste extract)

Contaminated debris and soil (pesticide/herbicide) [SOILPT]

Testing Required


Toxicity, leachate

Onsite treatment (with activated carbon) Landfill at an approved Class Ia, Ib, or II landfill, depending on specific characteristics

Consult the Industrial Vegetation Management Association of Alberta’s Field Manual for Rehabilitating Soils Affected by Residual Herbicides, April 1987

Contaminated debris and soil (produced/ salt water) [SOILPW]


Onsite treatment Send to an approved oilfield waste processing facility for soil washing Landfill at an approved Class Ia, Ib, or II landfill

Contaminated debris and soil (refined fuels/oils) [SOILRO]

Testing Required



Biodegredation onsite (or offsite at an approved facility) Send to an approved oilfield waste processing facility Thermal treatment

Contaminated debris and soil (sulfur) [SOILSU]

N-DOW Not TDG regulated (unless contaminated with a DOW)

Onsite treatment Landfill at an approved Class Ia, Ib, or II landfill (add lime to neutralize at time of burial)

See AEP’s Guidelines for the Disposal of Sulphur Containing Solid Wastes, March 1983

Corrosion inhibitor/ oxygen scavenger solutions [CORINH]


Heavy metals Inject down EUB Class Ib disposal well (if heavy metal limits are not exceeded) Inject down EUB Class Ia disposal well (if heavy metal limits exceeded)




Oilfield Class


Common Criteria


Crude oil/ condensate emulsions (residuals after treatment) [COEMUL]

See Comments

Class 3, UN1267


Send to an approved oilfield waste processing facility Inject down EUN Class Ia or Ib disposal well Cavern disposal Thermal treatment Biodegradation

Normally not a DOW (depending on flash point and BTEX content) All reasonable efforts must be made to recover hydrocarbon prior to disposal See EUB Guide 51 for injection well requirements

Desiccant [DESICT]

Testing Required

DOW: Class 9.3 NA 9500 N-DOW: Not TDG regulated

Corrosivity, flash point, leachate

DOW: Reuse/regenerate Containerize and landfill at an approved Class Ia or Ib landfill N-DOW: Reuse/ regenerate Recycle (construction fill) Containerize and landfill at an approved Class Ia, Ib or II landfill

This waste may be DOW depending on leachate characteristics (BTEX); if BTEX >1000 mg/kg, it cannot be landfilled

Dimethyl disulphide solutions [DMDS]

DOW Class 3, UN 2331

Flash point, toxicity

Reuse, if possible Return to supplier Inject down EUB Class Ia disposal well

Drilling sump materials (gel chem) [SUMPGL]


Disposal in accordance with EUB Guide 50

See EUB Guide 50 for specific disposal requirements

Drilling sump materials (hydrocarbon) [SUMPIN]

See Comments



Disposal in accordance with EUB Guide 50

Normally not a DOW (depending on flash point and BTEX) Obtain EUB approval prior to disposal See EUB Guide 50 for specific disposal requirements



Oilfield Class


Common Criteria


Drilling sump materials (KCL) [SUMPKC]

N-DOW Dependent on specific characteristics; consult TDG regulations

Disposal in accordance with EUB Guide G-50 (revised)

See EUB Guide 50 for specific disposal requirements Obtain EUB approval prior to disposal

Filter backwash liquids (gas sweetening) [FLBWSW]

DOW Dependent on specific characteristics; consult TDG regulations

Leachate Inject down EUB Class Ia or Ib disposal well


Filter backwash liquids (water treatment) [FLBWWT]


Reuse Recycle (land irrigation) Return to source Inject down EUB Class Ia or Ib disposal well

See EUB Guide 51 for injection well requirements High sediment and organic content would require downhole injection

Filters glycol [FILGLY]


Flash point, pyrophoric characteristics leachate

Recycle (metal recovery) Thermal treatment Drain liquids, containerize to prevent contact with air, and landfill at an approved Class Ia or Ib landfill

CAPP has developed a sampling and testing protocol for waste filters Recovered entrained liquids are DOW, and should be recycled or injected down an EUB Class Ia or Ib disposal well See EUB Guide 51 for injection well requirements

Filters (media) – water treatment

Testing Required



DOW: Reuse/ regenerate Containerize and landfill at an approved Class Ia or Ib landfill N-DOW: Reuse/regenerate Recycle (construction fill) Containerize and

This waste may be DOW, depending on leachate characteristics; if BTEX >1000 mg/kg, it cannot be landfilled



Oilfield Class


Common Criteria


landfill at an approved Class Ia, Ib, or II landfill, depending on specific characteristics

Filters – air pollution control [FILAPC]

Testing Required


Biodegradation Thermal treatment Landfill to an approved Class Ia, Ib, or II landfill, depending on specific characteristics

Normally not a DOW (depending on leachate characteristics)

Filters – gas sweetening (MEA, DEA, MDEA, sulphinol) [FILSWT]




CAPP has developed a sampling and testing protocol for waste filters Recovered entrained liquids are DOW and should be recycled or injected down an EUB Class Ia or Ib disposal well See EUB Guide 51 for injection well requirements

Filters – lube oil (waste type 201) [FILLUB]

Undrained: DOW Drained: N-DOW

Dependent on specific characteristics; consult TDG regulations


Recycle (metal recovery) Thermal treatment Drain liquids, landfill at an approved Class Ia or Ib landfill

CAPP has developed a sampling and testing protocol for waste filters Internal combustion engine lube oil filters are N-DOW if they are fully drained and have a drainage efficiency (DE) >0.5 DE = (undrained weight – drained weight) ÷ (undrained weight – new filter weight) Recovered entrained liquids are DOW and should be recycled or injected down an EUB Class Ia or Ib



Oilfield Class


Common Criteria


disposal well See EUB Guide 51 for injection well requirements

Filters – methanol [FILMTH]



Recycle (metal recovery) Thermal treatment Drain liquids, landfill at an approved Class Ia or Ib landfill

CAPP has developed a sampling and testing protocol for waste filters Recovered entrained liquids are DOW and should be recycled or injected down an EUB Class Ia or Ib disposal well See EUB Guide G-51 for injection well requirements

Filters – other (raw/ fuel gas, NGLs) [FILOTH]





Filters – produced/ process water [FILPWT]





Filters – raw/ fresh N-DOW Not TDG Landfill at an



Oilfield Class


Common Criteria


water [FILFWT]

regulated approved Class Ia, Ib, II, or III landfill

Frac sand – non- radioactive [FRCSND]

See Comments



Recycle (return to supplier) Send to an approved oilfield waste processing facility for hydrocarbon recovery Containerize and landfill at an approved Class Ia, Ib, or II landfill, depending on specific characteristics

Normally not a DOW (depending on flash point or leachate characteristics); if BTEX >1000 mg/kg, the waste cannot be landfilled

Frac sand – radioactive (plus other radioactive diagnostic materials) [FRSDR]

See Comments

Class 7 Leachate Recycle (return to supplier) Bury onsite in accordance with Atomic Energy Control Board guidelines

See Part F, Section 31.0, for specific disposal procedures Radioactive materials must not be handled at a waste processing facility and cannot be road-disposed Radioactive frac sand is regulated by the Atomic Energy Control Board (AECB); AECB approval is required for any transportation or disposal of the waste Waste may be DOW after radioactive decay (heavy metal and radioactive tracer leachate characteristics)

Garbage/domestic waste [DOMWST]


Implement the 4R’s to reduce volumes (see Appendix 6) Landfill at an approved Class Ia, Ib, II, or III landfill

Glycol solutions DOW Dependent on Flash point, Recycle Glycol solutions from



Oilfield Class


Common Criteria


(containing lead or other heavy metals) (Waste Type #202) [GLYCHM]

specific waste characteristics; consult TDG regulations

toxicity (heavy metals)

Inject down EUB Class Ia disposal well (glycol <40% by mass)

vessels containing lead solder Identified as Waste Type #202 in AEP’s Alberta User Guide for Waste Managers, May 1995 See EUB Guide 51 for injection well requirements

Glycol solutions (no heavy metals) [GLYC]

Testing Required



Recycle Inject down EUB Class Ia or Ib disposal well (glycol <40% by mass)

May be a DOW, depending on flash point and toxicity See EUB Guide 51 for injection well requirements

Hydraulic and transmission oil [HYDOIL]

See Comments


Heavy metals Direct to a licensed lube oil recycling firm Thermal treatment

Normally not a DOW (depending on heavy metal content; i.e., Va, V)

Hydrotest fluids methanol [METHNL]

See Comments



Reuse Recycle Inject down EUB Class Ia or Ib disposal well (organics <10% by mass)


Incinerator ash [INCASH]

Testing Required


Leachate (heavy metals)

DOW: Landfill at an approved Class Ia or Ib landfill N-DOW: Recycle (construction fill) Landfill at an approved Class Ia, Ib, or II landfill Physical/chemical treatment

Ion exchange resin [IEXRES]

N-DOW Dependent on specific waste characteristics;

Containerize and landfill at an approved Class Ia, Ib, or II



Oilfield Class


Common Criteria


consult TDG regulations

landfill

Ion exchange resin regenerant liquids {IEXLIQ]

See Comments


Inject down EUB Class Ia disposal well (pH 4.5–12.5) Inject down EUB Class Ib disposal well (pH 6.0–9.0)

Normally not a DOW (depending on pH) See EUB Guide 51 for injection well requirements

Iron sponge [IRNSPG]

DOW Class 4.2, UNI1376

Pyrophoric characteristics leachate

Keep wet to avoid spontaneous combustion; isolate from acidic solutions Reuse/regenerate Landfill at an approved Class Ia or Ib landfill (add lime or equivalent at time of burial to neutralize)

Waste may be susceptible to spontaneous combustion – this material should be kept wet at all times See AEP’s Guidelines for the Disposal of Sulphur Containing Solid Wastes

Lead-based products (H2S sensing tape) [LDTAPE]

DOW Class 6.1 (9.2), UN1616

Heavy metals (Pb)

Landfill at an approved Class Ia or Ib landfill

Lead-based products (pipe dope/greases) [LDDOPE]


Heavy metals (Pb)

Recycle (if possible) Thermal treatment Landfill at an approved Class Ia or Ib landfil

Lubricating oil (hydrocarbon and synthetic) [LUBOIL]

See Comments


Heavy metals, flash point

Direct to a licensed lube oil recycling facility Thermal treatment

Normally not a DOW (depending on heavy metal content, i.e., Va, V)

Metal (scrap) [SMETAL]

See Comments


DOW: Decontaminate and recycle via a scrap metal dealer Landfill at an approved Class Ia or Ib landfill N-DOW: Recycle via a scrap metal dealer

Normally not a DOW (unless contaminated with sulfur, chemicals, oil, or other DOW wastes)



Oilfield Class


Common Criteria


Landfill via a scrap metal dealer Landfill at an approved Class Ia, Ib, II, or III landfill

Naturally occurring radioactive materials – NORM [NORM]

DOW Class 7 Toxicity General disposal guidelines as given in the Alberta Labour guidelines, Guidelines for the Handling of Naturally Occurring Radioactive Materials (NORM) in Western Canada

See Part F, Section 31.0 for specific disposal procedures General guidelines for the handling and disposal of NORM waste have been developed by the Western Canada NORM Committee: Guidelines for the Handling of Naturally Occurring Radioactive Materials (NORM) in Western Canada, which is available from Alberta Labour

Paints [WPAINT] DOW Class 3, UN1263 (if flammable) Class 8, UN3066 (if corrosive)

Toxicity, flash point, heavy metals

Physical/chemical treatment Thermal treatment Recycle (if possible) Approved toxic roundup (if small volumes)

Pesticides/ herbicides [PSTHRB]


Toxicity Avoid excessive volumes Waste material exchange programs Thermal treatment Approved toxic roundup (if small volumes)

Utilize third-party certified applicators for the application and disposal of pesticides, when possible

Pigging waste l and wax [PIGWST]

Testing Required

Dependent on specific waste characteristics; consult TDG

Flash point, pyrophoric characteristics

Send to an approved oilfield waste processing facility for hydrocarbon recovery



Oilfield Class


Common Criteria


regulations Thermal treatment Cavern disposal Landfill at an approved Class Ia or Ib landfill (must be solid)

Polychlorinated biphenyls (PCBs) –askarel liquids [PCBLIQ]

DOW Class 9.1, 9.2, UN2315

Toxicity Direct to an approved hazardous waste disposal facility

Polychlorinated biphenyls (PCBs) – contaminated solids <50 ppm [PCBSLF]


Landfill at an approved Class Ia or Ib landfill

Polychlorinated biphenyls (PCBs) – contaminated solids >1,000 ppm [PCBSGI]

DOW Class 9.1, 9.2, UN2315

Toxicity Direct to an approved hazardous waste disposal facility

Polychlorinated biphenyls (PCBs) – contaminated solids >50 ppm and <1,000 ppm [PCBSLI]

DOW Class 9.1, 9.2, UN2315

Toxicity Direct to an approved hazardous waste disposal facility Landfill at an approved Class Ia or Ib landfill

Polychlorinated biphenyls (PCBs) – fluorescent light ballasts [PCBBAL]

DOW Class 9.1, 9.2, UN2315

Toxicity Direct to an approved hazardous waste disposal facility Recycle metal component, if possible

Rags [OILRAG] See Comments


Reuse via laundering/ dry-cleaning Remove entrained liquids and landfill at an approved Class Ia, Ib, or II landfill, depending on specific characteristics

Normally not a DOW (depending on flash point or leachate); if BTEX >1000 mg/kg, it cannot be landfilled



Oilfield Class


Common Criteria


Salt heat medium [SALT]

See Comments

Depending on specific waste characteristics; consult TDG regulations

Solubilize using an existing aqueous waste stream and inject down an EUB Class Ia or Ib disposal well Physical/chemical treatment

Normally not a DOW (unless a strong oxidizer such as potassium or sodium salts) See EUB Guide 51 for injection well requirements

Sand – produced [SAND]

See Comments

Class 4.1, UN3175

Send to an approved oilfield waste processing facility for hydrocarbon recovery Recycle (other industrial uses) Use in road construction in accordance with EUB IL 95-04 Cavern disposal Landfill at an approved Class Ia, Ib, or II landfill, depending on specific characteristics

Normally not a DOW (depending on flash point or leachate characteristics); if BTEX >1000 mg/kg, it cannot be landfilled

Sludge – cooling tower [SLGCTW]


Leachate (heavy metals)

Physical/chemical treatment Cavern disposal

May be Waste Type 204, if hexavalent chromium used as a biocide in cooling waters

Sludge – flare pit [SLGPIT]

Testing Required



Disposal is based on specific waste characteristics determined from analytical or historical data Disposal options include: Physical, chemical treatment Approved Class Ia, Ib, or II landfill, depending on specific characteristics



Oilfield Class


Common Criteria


Biodegradation (onsite or offsite at an approved facility) Thermal treatment Approved oilfield waste processing facility

Sludge – gas sweetening systems [SLGSWT]



Disposal is based on specific waste characteristics determined from analytical or historical data Disposal options include: Physical/chemical treatment Approved Class Ia or Ib landfill Biodegradation Thermal treatment

Sludge – glycol/gas drying [SLGGLY]



Disposal is based on specific waste characteristics determined from analytical or historical data Disposal options include: Physical/chemical treatment Biodegradation Thermal treatment Inject down EUB Class Ia or Ib disposal well (glycol <40% by mass)

Sludge – hydrocarbon [SLGHYD]

Testing Required

Dependent on specific waste characteristics;


Disposal is based on specific waste characteristics



Oilfield Class


Common Criteria



determined from analytical or historical data Disposal options include: Approved oilfield waste processing facility Physical/chemical treatment Biodegradation Thermal treatment Approved Class Ia, Ib, or II landfill, depending on specific characteristics

Sludge – lime [SLGLIM]

Testing Required


Corrosivity Co-dispose with sulfur-containing wastes or soil at an approved Class Ia, Ib, or II landfill, depending on specific characteristics

DOW if pH >12.5

Sludge – process [SLGPRO]

Testing Required


Leachate Disposal is based on specific waste charac-teristics determined from analytical or historical data Disposal options include: Physical/chemical treatment Approved Class Ia, Ib, or II landfill, depending on specific characteristics Biodegradation Thermal treatment

Sludge – sulfur [SLGSUL]

Testing Required

Dependent on specific waste characteristics;

Leachate, corrosivity

Co-dispose with slightly basic wastes or soil at an approved

See AEP’s Guidelines for the Disposal of Sulphur Containing



Oilfield Class


Common Criteria



Class Ia, Ib, or II landfill, depending on specific characteristics Physical/chemical treatment

Solid Waste, March 1983

Sweetening agents (solids) [SWTSOL]

See Comments


Landfill at an approved Class Ia, Ib, or II landfill, depending on specific characteristics

Normally not a DOW (depending on leachate characteristics)

Thread protectors – casing/tubing [THPROT]


Reuse (return to pipe supplier) Recycle Landfill at an approved Class Ia, Ib, II or III landfill

Treater hay [TRTHAY]

See Comments


Flash point, pyrophoric characteristics

Direct to an approved oilfield waste processing facility for hydrocarbon recovery Thermal treatment

May be a DOW, depending on flash point or leachate characteristics

Wash fluids – organic [WSHORG]

Testing Required


Flash point, halogenated organics content, toxicity

Recycle (regenerate, alternate uses) Recover hydrocarbons and inject down EUB Class Ia or Ib disposal well Thermal treatment


Wash fluids – water [WSHWTR]

See Comments


Recover hydrocarbons and inject down EUB Class Ia or Ib disposal well

Normally not a DOW (depending on organic content, flash point, pH) See EUB Guide 51 for injection well requirements

Water process (with organic chemicals) [PWTROR]

Testing Required

Dependent on specific waste characteristics; consult TDG

Flash point, halogenated organics content,

Inject down EUB Class Ia disposal well (pH 4.5–12.5)




Oilfield Class


Common Criteria


regulations toxicity Inject down EUB Class Ib disposal well (pH 6.0–9.0)

Water – process (with heavy metals) [PWTRHM]


Heavy metals, pH

Inject down EUB Class Ia disposal well (pH 4.5–12.5) Inject down EUB Class Ib disposal well (pH 6.0–9.0) (if heavy metal content meets criteria outlined in EUB Guide 51


Water – produced (including brine solutions) [WATER]

N-DOW Not TDG regulated (unless contaminated with a DOW)

Recycle (water flood) Recover hydrocarbons and inject down EUB Class Ia, Ib, or II disposal well


Well workover fluids [WWOFLD]

See Comments


Corrosivity, flash point

Inject down EUB Class Ia disposal well (pH 4.5–12.5) Inject down EUB Class Ib disposal well (pH 6.0–9.0) Recover any hydrocarbons prior to disposal

See EUB Guide 51 for injection well requirements Heavy metals are not normally a concern for well servicing fluids

Wood (chemically treated/cooling tower) [WOODCT]

See Comments


Heavy metals, leachate

Landfill at an approved Class Ia, Ib, or II landfill, depending on specific characteristics

Normally not a DOW (unless in dispersed form and due to leachate characteristics and/or pentachlorophenol content)

Aerosol cans [EMTCON]


Recycle (if possible) Ensure containers are empty and landfill at an approved Class Ia, Ib, or II landfill

Barrels, pails [EMTCON]

See Comments

Dependent on previous contents; consult TDG

Reuse/return to supplier Recycle (barrel/

Normally not a DOW (see Section 5.3) Containers must be



Oilfield Class


Common Criteria


regulations container reconditioning) Rinse (see Section 5.3), crush and landfill at an approved Class Ia, Ib, or II landfill

completely empty (see Section 5.3)

Crude oil sample bottles [EMTCON]

N-DOW Class 3, UN1267

Reuse Recycle (commercial bottle washing facility or a plastic/glass recycling facility) Rinse and landfill at an approved Class Ia, Ib, or II landfill

Cutting oil tubes [EMTCON]


Landfill at an approved Class Ia, Ib, or II landfill

Grease cartridges [EMTCON]


Landfill at an approved Class Ia, Ib, or II landfill

Mud sacks – drilling [EMTCON]


Reuse (return to mud supplier) Landfill at an approved Class Ia, Ib, II, or III landfill Approved thermal treatment

Paint cans/brushes [EMTCON]

See Comments

Not TDG regulated (if dry)

Toxicity Allow residue to dry and landfill at an approved Class Ia, Ib, or II landfill

Not a DOW if empty and dry

Pesticide/herbicide containers

DOW Dependent on specific waste characteristics; consult TDG regulations or supplier of pesticide

Toxicity Recycle (pesticide container collection site) Rinse (see Section 5.3), crush, puncture, and landfill at an approved Class Ia, Ib, or II landfill with a designated pesticide

Containers must be completely empty and rinsed (see Section 5.3)



Oilfield Class


Common Criteria


container collection site

Pipe dope containers/brushes [EMTCON]

See Comments


Heavy metals Reuse (if possible) Rinse (see Section 5.3) and landfill at an approved Class Ia, Ib, or II landfill, depending on specific characteristics

Not a DOW if empty and dry

Miscellaneous Wastes Waste compressed or liquefied gases [WSTCGS]

Dependent on specific waste

Dependent on specific waste Class 2



Waste flammable liquid [WSTFLQ]



Flammability Dependent on specific waste

Waste flammable solid [WSTFSD]



Flammability Dependent on specific waste

Waste oxidizing liquid [WSTOLQ]



Oxidizes Dependent on specific waste

Waste oxidizing solid [WSTOSD]



Oxidizes Dependent on specific waste

Waste poisonous liquid [WSTPLQ]



Toxicity Dependent on specific waste

Waste poisonous solid [WSTPSD]




Waste radioactive material [WSTRDM]






Oilfield Class


Common Criteria


Waste corrosive liquid [WSTCLQ]



Toxicity, corrosivity


Waste corrosive solid [WSTCSO]



Corrosivity Dependent on specific waste

Waste – miscellaneous [WSTMIS]




Appendix 6: World Bank Group 6-1

APPENDIX 6: WORLD BANK GROUP The World Bank Group consists of five organizations: (1) the International Bank for Reconstruction and Development (IBRD); (2) the International Development Association (IDA); (3) the International Finance Corporation (IFC); (4) the Multilateral Investment Guarantee Agency (MIGA); and (5) the International Centre for Settlement of Investment Disputes (ICSID). The World Bank is the name most commonly used for the IBRD and the IDA. The World Bank is not a bank in the traditional sense. It is a specialized agency of the United Nations. The World Bank is made up of 184 member countries that share the responsibility for financing the institution and disbursing the funds.

• The IBRD (together with the IDA) provides low-interest loans, interest-free credit, and grants to developing countries.

o Fiscal year 2003 lending: $11.2 billion for 99 new operations in 37 countries. o IBRD operations are directed at reducing poverty in middle-income and

creditworthy poorer countries through loans, guarantees, and non-lending (analytical and advisory) services. The IBRD does not maximize profit, but has earned a net income each year. The profits fund developmental activities and enable low-cost borrowings in capital markets. Owned by member countries, the IBRD links voting power to members’ capital subscriptions.

• The IDA (together with the IBRD) provides low-interest loans, interest-free credit, and

grants to developing countries. o Fiscal year 2003 lending: $7.3 billion for 141 new operations in 55 countries. o Contributions to IDA enable the World Bank to provide $7 billion per year in

interest-free credits to the world’s 81 poorest countries. The IDA helps provide access to better basic services (education, health care, and clean water and sanitation) and supports reforms and investments directed at productivity growth and employment creation.

• The IFC promotes private sector investment by supporting high-risk sectors and

countries. o Fiscal year 2003 commitments: $3.9 billion (includes syndications, $3.9 billion

for own account) in 204 companies for 64 countries. o The IFC is entrusted with the mandate to further economic development through

the private sector. Working with business partners, it invests in sustainable private enterprises in developing countries and provides long-term loans, guarantees, and risk-management and advisory services to its clients.

• The MIGA provides political risk insurance (guarantees) to investors in and lenders to

developing countries. o Fiscal year 2003 guarantees issued: $1.4 billion (including $136 million leveraged

through the Cooperative Underwriting Program). o The MIGA helps encourage foreign investment in developing countries by

providing guarantees to foreign investors against losses caused by noncommercial risks (such as expropriation, currency inconvertibility and transfer restrictions,


and war and civil disturbances). Furthermore, the MIGA provides technical assistance to help countries disseminate information on investment opportunities. The agency also offers investment dispute mediation, on request.

• The ICSID settles investment disputes between foreign investors and their host countries.

o Fiscal year 2003 cases registered: 26. o The ICSID helps to encourage foreign investment by providing international

facilities for conciliation and arbitration of investment disputes between states and foreign investors. Many international agreements concerning investment refer to arbitration facilities under the auspices of the ICSID. The ICSID also conducts research and publishes in the areas of arbitration law and foreign investment law.

6.1 ENVIRONMENTAL POLICIES AND PROJECTS WITH WASTE

MANAGEMENT COMPONENTS Protecting the environment is one of six main principles in the World Bank’s mission to alleviate poverty and sustain the quality of development. In 2001, the World Bank Board of Directors endorsed an environmental strategy to guide the activities in the environmental arena over the next five years. The strategy emphasizes the three objectives of improving the quality of life, improving the quality of growth, and protecting the quality of the regional and global commons. Lending for environmental activities has been increasing. At the end of fiscal year 2001, for example, the World Bank had a core portfolio of projects with primarily environmental objectives of $5.1 billion and a broader portfolio of projects with environmental objectives or components worth about $13 billion. The core portfolio focuses on natural resource management, pollution/waste management, and institutional development activities. The broader portfolio includes selected projects or project components that include agriculture, energy, urban development, and water supply and sanitation sectors. The environmental and social requirements developed by the IFC have become the global benchmark for investment in emerging markets. The Environmentally and Socially Sustainable Development (ESSD) Network houses the “Environment Family,” which consists of various units or departments participating in the Environment Board:

• Regional Environment Units o Sub-Saharan Africa (AFR) o East Asia and Pacific (EAP) o Europe and Central Asia (ECA) o Latin America and the Caribbean Region (LCR) o Middle East and North Africa (MNA) o South Asia Region (SAR)

• Central Environment Department (Anchor)

• Other Environment Units

o World Bank Institute (WBI)


o Legal (LEG) o Development Economics (DEC) o IFC Environment Unit

• The World Bank Group, with the support and assistance of a wide range of agencies, governmental and nongovernmental organizations, and individuals, has developed and published various guidelines, technical guides, papers, manuals, and other reference materials for use in environmental projects with a waste management component:

• Pollution Prevention and Abatement Handbook (PPAH): o The PPAH went into official use on July 1, 1998 (updating and replacing the

1988 Environmental Guidelines). The PPAH promotes the concepts of sustainable development by focusing attention on the environmental and economic benefits of pollution prevention, including cleaner production and good management techniques.

o Part I contains a summary of key policy lessons in pollution management derived from practical experience inside and outside the World Bank Group over the past decade.

o Part II presents good-practice notes on implementation of policy objectives, based on experience with projects and lessons from the policies and practices of other agencies and organizations in this field.

o Part III offers detailed industry sector guidelines that are to be applied in the preparation of projects. In the absence of a sector-specific guideline for a particular project, general environmental guidelines are provided:

Oil and Gas Development (onshore) (1998). General Environmental Guidelines (1998).

• IFC Environmental Health and Safety Guidelines: The IFC has issued a series of specific

environmental health and safety guidelines. For IFC projects that do not fall under an industry sector guideline, the occupational health and safety guideline will be applied, subject to the modifications deemed necessary to suit the project:

o Oil and Gas Development (offshore) (2000). o Waste Management Facilities (1998). o Environmental Guideline for Occupational Health and Safety (2003).

• Technical Guides, Papers, and Manuals:

o Strategic Planning Guide for Municipal Solid Waste Management (2001). o Guidance Pack – Private Sector Participation in Municipal Solid Waste

Management (2000). o Solid Waste Landfills in Middle and Lower Income Countries (1999). o Decision-Maker’s Guide to Solid Waste Landfills (1999). o Decision-Maker’s Guide to Municipal Solid Waste Incineration (2000). o “Conceptual Framework for Municipal Solid Waste Management in Low-Income

Countries,” Working Paper No. 9 (1996). o “The Safe Disposal of Hazardous Wastes – The Special Needs and Problems of

Developing Countries,” Technical Paper No. 93, Vols. I, II, and III (1989).


o “Health Care Waste Management Guidance Note” (2000).

• Other Reference Materials: o Sustainable Development Sourcebook for the World Bank Group’s Extractive

Industries Review: Examining the Social and Environmental Impacts of Oil, Gas, and Mining (2004).

6.2 WASTE CLASSIFICATION The definitions presented in this section have been extracted from the glossaries and narratives of various source documents. 6.2.1 Waste Waste includes unwanted materials left over from human activity and refuse from places of human or animal habitation. Waste may be generically defined as a heterogeneous mixture of material that is discarded as superfluous and has no further use or value to its owner. In waste planning, there are various categorizations of waste, including municipal solid waste, controlled waste, and hazardous waste. 6.2.2 Wastes Associated with Oil and Gas Production The main waste streams associated with oil and gas production include drilling-waste fluids (muds), drilling-waste solids, produced water, and volatile organic compounds:

• The drilling-waste muds involve freshwater gel, saltwater (potassium chloride), or oil invert-based systems (containing up to 50% diesel oil by volume). Drilling wastes may contain drilling muds (bentonite), borehole cuttings, additives (polymers, oxygen scavengers, biocides, and surfactants), lubricants, diesel oil, emulsifying agents, and other wastes related to drilling activities. Drilling-waste solids, which are made up of the bottom layer of drilling-mud sump materials, may contain drill cuttings, flocculated bentonite, and weighting materials and other additives. Additional wastes from the drilling process include used oils, cementing chemicals, and toxic organic compounds.

• Field processing of crude oil generates several waste streams, including contaminated

wastewater (which typically contains suspended solids), tank bottoms (which may contain lead), emulsions, and heavy hydrocarbon residues (which may contain polynuclear aromatic hydrocarbons [PAHs]). In addition, cooling tower blowdown, boiler water, scrubber liquids, steam production wastes, contaminated soil, used oil, and spent solvents are generated.

6.2.3 Municipal Solid Waste (MSW) MSW includes nonhazardous waste generated in households, commercial and business establishments, institutions, and nonhazardous industrial process wastes, agricultural wastes, and sewage sludge. In practice, specific definitions vary across jurisdictions. MSW is a


heterogeneous mixture of different types of discarded materials. The composition of MSW depends on the conditions of the city in question. In general, MSW is composed of the following fractions: paper, rubber, plastic, fabric, leather, vegetable/putrescible, wood, etc. (combustibles), coal ash, glass metal, etc. (non-combustibles). While hazardous industrial and medical wastes are, by definition, not components of municipal solid waste, they are normally quite difficult to separate from municipal solid waste, particularly when their sources are small and scattered. Solid waste is defined as MSW composed of solid matter from household, commercial, institutional, and industrial sources. (Technically, solid waste also refers to liquids and gases in containers.) Semisolid wastes such as sludge and nightsoil are considered to be the responsibility of liquid waste management systems. Bulky waste consists of large items of MSW including, but not limited to, appliances, furniture, large auto parts, tree stumps, etc., which cannot be handled by normal municipal waste management methods. MSW source subcategories include household or domestic waste, residential waste, yard waste, commercial waste, institutional waste, packaging waste, agricultural waste, sewage sludge, construction and demolition waste, certain medical waste, and sanitation residues:

• Household or domestic waste: MSW composed of garbage and rubbish (trash) that is generated as the consequence of household activities. In developing countries, up to two thirds of this category consists of the putrescible fraction of MSW. In poor neighborhoods, traditional cooking can also produce ash, and where sanitation facilities are limited, the waste might also include fecal matter. Domestic waste may contain a significant amount of hazardous waste.

• Residential waste: MSW generated in single- and multiple-family homes. • Yard waste: The part of MSW composed of grass clippings, leaves, twigs, branches, and

garden refuse. • Commercial waste: All MSW emanating from business establishments such as stores,

markets, office buildings, restaurants, shopping centers, and entertainment centers.

• Institutional waste: Waste originating in schools, hospitals, prisons, research organizations, and other public buildings. Where the institution involves residents, the waste composition is similar to that of households.

• Street sweepings: Dominated by dust and soil, together with various amounts of paper,

metal, and other litter that is picked up from the streets. It may also include drain cleanings, household waste dumped at the side of the road, plant remains, and animal manure.

• Packaging waste: Material discarded after the product in the packaged materials has

been removed for use. Such waste is discarded by residential, commercial, and industrial sectors.


• Agricultural waste: Farming wastes, including runoff and leaching of pesticides and fertilizers, erosion and dust from plowing, improper disposal of animal manure and carcasses, crop residues, and debris.

• Sewage sludge: Sludge generated at a municipal wastewater treatment facility. It usually

refers to secondary sludge settled after biological treatment is completed. Often accepted for disposal at a landfill.

• Construction and demolition waste: MSW originated from or use of building materials,

dredging materials, tree stumps, and rubble resulting from construction, remodeling, repair, and demolition of homes, commercial buildings, and other structures and pavements. The nature of this MSW depends on the resources used in a given region or country for the purposes of construction. In the absence of adequate local ordinance, the responsibility for the management of these wastes is invariably assumed to lie with the municipality.

• Medical waste: Any MSW generated in the diagnosis, treatment, or immunization of

human beings or animals.

• Sanitation residues: These are human excreta residues collected from privies and latrines (often called nightsoil) which, depending on the level of sewerage provided, may be dumped in street drains, and therefore arise in drain-clearing and street-sweeping wastes.

6.2.4 Hazardous Waste Waste generated during production or other activities by society that can pose a substantial or potential hazard to human health or the environment when improperly managed. Hazardous waste possesses at least one of four characteristics (ignitability, corrosivity, reactivity, or toxicity) or appears on special listings (particular types of hazardous wastes; industrial processes from which the wastes are defined as hazardous; and substances, either specific or classes, the presence of which is indicative of a potential human-health or environmental hazard). A number of specific exclusions pertain to wastes that are controlled by separate legal frameworks, for example, radioactive wastes and domestic refuse. Jurisdictions also exclude small-quantity wastes (by threshold) and certain high-volume/low-hazard wastes (for example, mining wastes and agricultural wastes) from coverage under the hazardous waste regulation. World Bank Technical Paper No. 93 offers a waste classification scheme linking waste types to industrial categories:

• Waste types o Inorganic wastes

Acid and alkalis Cyanide wastes Heavy metal sludges and solution


Asbestos wastes Other solid residues

o Oily wastes o Organic wastes

Halogenated solvents Non-halogenated solvent wastes PCB wastes Paint and resin wastes Biocide wastes Organic chemical residues

o Putrescible organic wastes o High-volume/low-hazard wastes o Miscellaneous wastes

Infectious wastes Laboratory wastes Explosive wastes

• Industrial groups

o A Agriculture, forestry, and food production o B Mineral extraction o C Energy (includes oil and gas extraction) o D Metal manufacture o E Manufacture of non-metal mineral products o F Chemical and related industries o G Metal, engineering, and vehicle industries o H Textile, leather, timber, and wood industries o J Manufacture of paper and products, printing and publishing o K Medical, sanitary, and other health services o L Commercial and personal services.

6.2.5 Industrial Waste A heterogeneous mixture of different materials generated during an industrial operation. It may be gaseous, liquid, sludge, and/or solid. The composition is site-specific and depends upon the natural resources, raw materials, and markets that provide the base for a given city’s industrial activity. 6.2.6 Health Care Wastes Health care waste (HCW) arises from the practice of medicine, including dentistry, alternative medicine (such as acupuncture), medical laboratories, home treatment, and veterinary practices. Most health care waste is no more hazardous than domestic wastes, but some can be very dangerous. It is important to remember that health care wastes do not only come from large hospitals but also from small clinics and nursing homes, and even individual dwellings.


The Health Care Waste Guidance Note, based on technical guidelines issued by the World Health Organization, defines HCW as the total waste stream from health care establishments, research facilities, laboratories, and emergency relief donations. HCW includes several different waste streams, some of which require more stringent care and disposal. HCW can be divided into no-risk health care waste and special health care waste:

• No-risk health care waste includes all waste comparable to domestic waste, such as packaging materials, noninfectious bedding, building rubble/demolition waste, hotel function waste (household, kitchen, administration), and other such wastes generated from patient wards and other patient care not related to medical care.

• Special health care waste always needs special attention and includes:

o Sharps. All sharp objects that could cause a cut or puncture (whether infectious or not) including hypodermic needles, suture needles, injector tips, scalpels, lancets, knives, blades, razors, pipettes, and broken glass (non-exhaustive list).

o Pathological waste. Body tissues, organs, body parts, human fetuses, animal carcasses, liquid waste blood, plasma, coagulated factors, and body fluids.

o Redundant potential infectious waste. Disposable items contaminated with excreta, dressings, gowns, gloves, etc., containers with blood products, I.V. tubing, emptied peripheral dialysis fluid bags, intravascular access devices introducers, culture dishes, microbiological slides and cover slips, test tubes, vials, vacutainers, etc.

o Hazardous chemical waste. Any substance, liquid or solid, with at least one of the following properties: explosive, flammable, toxic, corrosive, locally chafing, reactive, or genotoxic (carcinogenic, mutagenic, teratogenic), including cytotoxic drugs. Also, all containers contaminated by these substances.

o Pharmaceutical waste. All pharmaceutical products, drugs, drug residuals, and therapeutic chemicals that have been returned from wards; have been spilled; are outdated or contaminated; or are to be discharged because they are no longer required. Particular attention should be given to these wastes in the segregation process, as they may otherwise be resold by waste pickers.

o Radioactive waste. Solids, liquids, and gaseous waste contaminated with radionuclides. This type of waste is generated from in vitro analysis of body tissues and fluids, in vivo body organ imaging and tumor localization, and investigative and therapeutic procedures.

o Pressurized containers. Containers holding gases used for anesthesia, oxygen delivery, or cleaning mechanisms. Can include gas cylinders, cartridges, and disposable aerosol cans. The most common types of gas are ethylene oxide, oxygen, and compressed air.

World Bank Technical Paper No. 93 contains a definition of biomedical waste developed by the Ontario Ministry of the Environment. It refers to any waste that includes anatomical waste, pathological waste, infectious waste, hazardous waste, and other waste generated in health care facilities and medical laboratories that requires special handling. Previously, the terms pathological and institutional wastes were used to refer to what is now considered biomedical waste. Table 6-1 summarizes the classification system used by the ministry.


Table 6-1 Ministry Classification and Color Coding for Biomedical Waste Classification Description Color Code

Type A, Class 1

Human anatomical Red

Type A, Class 2

Animal anatomical, infected Orange

Type A, Class 3a 3b 3c

Non-anatomical, infected Laboratory wastes Wastes from DNA work

Yellow

Type B, Class 1 Animal anatomical, non-infected Blue

6.3 WASTE MANAGEMENT GUIDELINES Waste management standards for the design and operation of each project must be established through the environmental assessment (EA) process on the basis of in-country legislation and the PPAH, subject to local conditions. The standards must be justified in the EA and acceptable to the World Bank Group. The relevant guidelines represent the standards normally acceptable to the World Bank Group when making decisions with respect to project assistance. Any deviation must be described in the project documentation. Dilution to achieve the guidelines is deemed unacceptable. All maximum levels should be achieved at least 95% of the time that the plant or unit is operating (to be calculated as a proportion of annual operating hours). 6.3.1 PPAH Industry Sector Guidelines for Oil and Gas Development (Onshore)

6.3.1.1 Liquid Effluents Table 6-2 presents the specific guidelines offered in the PPAH with respect to liquid effluents from onshore oil and gas production. Effluent requirements are for direct discharge to surface waters.

6.3.1.2 Monitoring, Recordkeeping, and Best Practices Liquid effluents from production operations should be analyzed for the parameters on a daily basis, except for metals, which can be monitored monthly or when significant process changes occur. Monitoring data should be analyzed and reviewed at regular intervals and compared with the operating standards so that corrective action can be taken, if necessary. Monitoring results should be recorded, and the results should be reported to the responsible authorities and relevant parties, as required.


Table 6-2 Liquid Effluents from Onshore Oil and Gas Production Parameter Maximum Value Comments

pH

6–9

BOD

50 mg/L

TSS

50 mg/L

Oil and grease 20 mg/L Up to 40 mg/L is acceptable for facilities producing less than 10,000 tons per day.

Phenol

1 mg/L

Sulfide

1 mg/L

Total toxic metals 5 mg/L Toxic metals include antimony, arsenic, beryllium, cadmium, chromium, copper, lead, mercury, nickel, selenium, silver, thallium, vanadium, and zinc.

Temperature increase <3oC The effluent should result in a temperature increase of no more than 3oC at the edge of the zone where initial mixing and dilution take place; where the zone is not defined, use 100 meters from the point of discharge.

The PPAH recommends several key control practices that will facilitate compliance with the guidelines, including:

• Maximize the use of freshwater gel-based mud systems. • Dispose of drilling muds in a manner that minimizes the impact on the environment;

reuse invert (diesel-based) muds. • Reuse drilling mud pond decant water. • Encourage the reuse of produced water for steam generation when steam is used to

stimulate reservoir production.


6.3.2 IFC Environmental, Health, and Safety Guidelines for Oil and Gas Development (Offshore)

The facilities and activities covered by the IFC guidelines include exploratory drilling as well as exploration and production activities. The guidelines do not cover seismic activities, onshore facilities, and onshore operations.

6.3.2.1 Liquid Effluents Table 6-3 presents the IFC guidelines for liquid effluents from offshore oil and gas drilling and recovery operations. Table 6-3 Effluents from Offshore Oil and Gas Production

Parameter Requirement Oil and grease 42 mg/L (daily average) [Note: these guidelines

follow the U.S. guidelines very closely, but the U.S. sets 42 mg/L as a daily maximum, not average]; 29 mg/L (monthly average)

Deck drainage No visible sheen

Drilling fluids and cutting – non-water-based

No discharge allowed except in compliance with 96-hr LC-50 of SPP-3% vol. toxicity test first for drilling fluids (Oil and Grease Test Method 1664 Revision A, employing normal hexane as the extracting solvent, as approved by the U.S. Environmental Protection Agency) or alternatively testing based upon site-specific species agreed with IFC Discharge via a caisson at least 15 m below sea surface

Drilling fluids and cutting – water-based

No discharge allowed except in compliance with 96-hr LC-50 of SPP-3% vol. toxicity test first for drilling fluids (Oil and Grease Test Method 1664 Revision A, employing normal hexane as the extracting solvent, as approved by the U.S. Environmental Protection Agency) or alternatively testing based upon site-specific species agreed with IFC Discharge via a caisson at least 15 m below sea surface Maximum chloride concentration must be less than four times the ambient concentration of fresh or brackish receiving water

Drilling fluids and cutting – diesel oil

No discharge allowed; can only be used to free stuck pipe in an emergency


Parameter Requirement Drilling fluids and cutting – additives and chemicals

No limitation except toxicity testing of chemicals for hazards Barite used will meet: Hg <1 mg/kg and Cd <3mg/kg dry weight (total) Products known or suspected to cause taint, endocrine disruption, or contain heavy metals will be avoided (a risk-based approach is recommended; equivalent screening procedures or risk evaluations may be acceptable to IFC)

Produced sand Discharge not permitted – reinject or take ashore

Produced water If separated and disposed at locations other than the platform, it must at a minimum meet these guidelines

Sanitary effluents and sink drains (gray water) Package treatment and chlorination to an average of 1 mg/L residual chlorine (because of concerns about chlorinated hydrocarbons, alternative forms of disinfection should be evaluated)

Cooling water The effluent should result in a temperature increase of no more than 3oC at the edge of the zone where initial mixing and dilution take place; where the zone is not defined, use 100 meters from the point of discharge

6.3.2.2 Solid Wastes Solid wastes, including packaging material, containers, discarded and damaged pipe and drill bits, and leftover construction materials, are to be taken ashore and recycled, reused, or disposed of.

6.3.2.3 Hazardous Wastes Hazardous wastes, including paint residues, solvents, batteries, mercury lamps, pig cleaning sludges, and contaminated chemicals from drilling and production operations, are to be taken to onshore facilities for treatment and disposal. The IFC guidelines recommend that efforts be made to eliminate, reduce, or recycle hazardous waste.

6.3.2.4 Naturally Occurring Radioactive Material (NORM) The IFC guidelines state that radiation surveys of equipment and sites should be conducted every five years or whenever equipment is to be taken out of service for maintenance. Facilities are considered impacted if surface levels are greater than 4.0 Bq/cm2 for gamma/beta radiation and 0.4.Bq/cm2 for alpha radiation. Where NORM-bearing scale is anticipated or found, scale


inhibitors and personal protective should be used. Sludge, scale, or NORM-impacted equipment with radium-226 must be treated, processed, or isolated so that the treated waste does not exceed the background radioactivity concentration of the disposal site by more than 5 pCi/g. In the alternative, the waste may be disposed of at a facility that is licensed to receive such waste.

6.3.2.5 Monitoring, Recordkeeping, and Best Practices Monitoring data should be reviewed and analyzed at regular intervals and compared with the operating standards so that corrective action, if necessary, can be taken. Monitoring results should be recorded, and the results should be reported to the responsible authorities and relevant parties, as required. Further sampling, chemical analysis, and toxicity testing may be required during startup and during upset conditions. Chemical testing should be conducted for oil and grease, using normal hexane or cyclohexane as the extracting solvent under the methods developed by the U.S. Environmental Protection Agency (EPA), including EPA methods 413.1, 9070, 9071A, and 1664 Revision A. Test methods using ozone-depleting solvents must not be used. Monitoring frequency should be as follows: at least once per month for effluents, and a radiation survey annually for contaminated sites and every three years for clean sites. Monitoring data and the radiation survey are subject to recordkeeping requirements. The IFC guidelines recommend environmental best practices that should be considered where appropriate. They fall into the areas of drilling management, produced water management, and chemical management:

• Drilling Management: o Reduce the hydrocarbon content of cuttings by mechanical, chemical, or thermal

treatment where possible; or transport them to shore for treatment or disposal; or consider annulus or downhole injection.

o Use enhanced solids control systems to reduce the amount of wastes from circulation systems and the amount of dilution.

o Develop and use chemicals with the lowest toxicity and the lowest levels of biologically available heavy metals and other hazardous substances, especially persistent organic chemicals and substances with a potential to bioaccumulate.

o Minimize and avoid, where possible, the use of toxic additives in drilling fluids.

• Produced Water Management: o Consider alternatives to surface discharge of produced water, including

reinjection, onshore treatment and disposal, and downhole separation of oil and water.

o Minimize the quantity and reduce the toxicity of discharged produced water. o Select the least hazardous chemicals to minimize produced water toxicity. o Reuse produced water and recover oil from process wastewater prior to disposal.

• Chemical Management:

o Use a chemical hazard assessment and risk management techniques to evaluate chemicals and their effects, and utilize the least toxic and hazardous chemicals (considering persistence and bioaccumulation).


o Use low-toxicity lubricant additives to reduce the overall toxicity of drilling fluids where possible.

6.3.3 Municipal Solid Waste

6.3.3.1 Municipal Solid Waste Incineration Municipal Solid Waste Incineration: A Decision Maker’s Guide outlines the advantages and disadvantages of municipal solid waste incineration. Incineration is described as an efficient way to decrease waste volume, reduce demand for landfill space, and recover energy. The disadvantages include heavy investments and high operating and maintenance costs. Incineration plant equipment is grouped into four principal categories, including pretreatment, combustion system, energy recovery, and flue gas cleaning. Incineration operations result in residues that must be properly managed.

6.3.3.2 Municipal Solid Waste Landfills The Decision-Maker’s Guide to Solid Waste Landfills notes that disposal of waste to land is an inevitable part of every solid waste management system. Any open dumping is considered unacceptable.

• Sanitary Landfills. Sanitary landfills are a type of municipal solid waste landfill. They are sites where wastes are isolated from the environment until they are safe. Sanitary landfills are characterized by four basic features.

o Full or Partial Hydrogeological Isolation. If a site cannot be located on land that naturally contains leachate security, liners (impermeable or semipermeable) should be employed to reduce leachate and protect surrounding soil and groundwater. Leachate collection and treatment should be in place.

o Formal Engineering Preparations. Designs should be developed from local geological and hydrogeological investigations. A waste tipping plan and a final restoration plan should also be developed.

o Permanent Control. Trained staff should be based at the landfill to supervise site preparation and construction, the depositing of the waste, and regular operations and maintenance.

o Planned Waste Emplacement and Covering. Waste should be spread in layers and compacted. A small working area that is covered daily helps make the waste less accessible to vermin and pests.

• Co-Disposal Landfills.

o Some industrial (hazardous) wastes are completely unacceptable in a co-disposal landfill because of their highly chemical nature or solubility.

The Decision-Maker’s Guide to Solid Waste Landfills identifies the following procedures and practices required at a well-managed landfill site:


• Waste should be deposited in thin, 0.5-meter bands, building up into layers not greater than about 2 meters in depth.

• The surface of the newly deposited waste should be covered at the end of each day with

approximately 15 centimeters of soil or similar material.

• No biodegradable waste should be deposited in water.

• Open burning should not be permitted.

• Frequent inspections for vermin should be made and measures taken to prevent infestations in order to reduce health risks.

• Frequent collection of litter from the site helps convey an impression of a well-managed

site.

• Drainage ditches should be kept clear to avoid problems during wet weather.

• Site access roads should be kept in good condition to allow vehicles to deposit their waste loads quickly and efficiently. Broken fences should be repaired and maintained to prevent animals from coming onto the site.

• The general public should be excluded from the site for their own safety.

• Records of waste deliveries to the site should be kept, showing who delivered the waste

at what times as well as waste types and quantities.

• Environmental monitoring must be conducted on a regular schedule. The records must be kept and maintained.

• Correct covering of the completed site is required. The primary aim of the final cap is to

minimize leachate generation by excluding rainwater and other surface water. A well-compacted and drained clay cap that is protected from soil erosion by vegetation will inhibit surface water from entering the site.

6.3.4 Hazardous Waste The PPAH describes components of a hazardous waste management system, including prevention, responsibility for hazardous wastes, storage of hazardous wastes, and hazardous waste treatment and disposal facilities:

• Prevention. Cost considerations create a powerful incentive for waste reduction and elimination. Where the generation of hazardous wastes cannot be eliminated, the PPAH recommends action to reduce hazardous characteristics through treatment or immobilization.


• Responsibility. An effective control system must be designed to protect the environment from illegal dumping and to internalize the disposal costs to waste generators in an equitable way. According to the PPAH, waste generators should be responsible for the final disposal of their wastes in acceptable manner. With respect to the three phases of generation, transportation, and disposal, the system elements created by law and regulations include placing responsibility on the generator to prove compliance with disposal requirements, licensing waste haulers and disposal facilities, and establishing a manifest system to track the movement of wastes.

• Hazardous Waste Storage. In the absence of approved or affordable disposal options,

storage is a common practice or stopgap measure taken by generators or transporters. According to the PPAH, regulations governing the storage of hazardous wastes at the generator’s site or at any other transfer or disposal facility should be designed to prevent neglected piles if deteriorating wastes. Hazardous waste managers should not be allowed to stockpile wastes over an extended period of time as a way of avoiding disposal problems.

• Hazardous Waste Treatment and Disposal Facilities. Hazardous waste management

facilities include storage, recovery, and treatment phases, as well as final disposition. The PPAH recommends that potential operators should be required to demonstrate the necessary technical, financial, and managerial capabilities before a license to operate is issued. Any discharges from the site to air or water need to be very closely controlled and monitored. Final disposition is almost always incineration or landfill.

• Hazardous Waste Landfills. The final disposition of many hazardous wastes and

hazardous waste residues, in the wake of all possible reduction and treatment, involves controlled land disposal. The PPAH identifies water pollution as the main challenge in landfilling operations. A landfill should therefore be sited where the geological and hydrological characteristics are least likely to allow impacts on groundwater and surface water. According to the PPAH, a well-designed, secure landfill is normally divided into a number of cells to allow for better control of operations and segregation of incompatible wastes. The landfill is lined, often with a double or even triple lining, and has leachate collection facilities and groundwater monitoring systems. The design should include provisions for the closure and long-term monitoring of the site. Operational requirements should govern pretreatment and containment of wastes, control and recording of the burial of different waste types, planning and preparation for spills and accidents, and regular monitoring of the surrounding environment. According to the PPAH, the joint disposal of domestic and certain selected industrial wastes in a properly designed and operated landfill may be acceptable as an interim management measure or in circumstances where the wastes in question (for example, waste motor oils or certain sludges) have been demonstrated to be compatible. The practice must never be used to circumvent the applicable requirements governing the proper management of these wastes.

• Other disposal options include land treatment (or land farming), surface impoundments,

and deep well injection.


6.3.5 Health Care Wastes Proper management of HCW can minimize the risks both within and outside health care facilities. The first priority is to segregate wastes, preferably at the point of generation, into reusable and nonreusable, hazardous and nonhazardous components. Other important steps are the institution of a sharps management system, waste reduction, avoidance of hazardous substances whenever possible (e.g. PVC-containing products, mercury thermometers), ensuring worker safety, providing secure methods of waste collection and transportation, and installing safe treatment and disposal mechanisms. Generally, there are four key steps to HCW management: (1) segregation into various components, including reusable and safe storage in appropriate containers; (2) transportation to waste treatment and disposal sites; (3) treatment; and (4) final disposition. The Health Care Waste Management Guidance Note compiles the treatment and final disposal technologies for special HCW.

• Incineration is an advanced technology that can adequately treat all types of special health care waste. The key parameters of controlled incineration are summarized as “TTT”: combustion at a sufficiently high temperature (between 1,000°C and 1,200°C in the combustion chamber) for a long enough time, in a combustion chamber with sufficient turbulence and oxygen for complete combustion to be achieved and problematic gases to be minimized. An incinerator requires skilled operators, extensive flue gas emission controls and, frequently, imported spares and supplies. Properly controlled incineration is relatively expensive. Incineration of wastes generates residues, including air emissions and ash. Environmental controls on incinerators in developed countries have been tightened in recent years, principally because of concerns over air emissions of pollutants such as dioxins and heavy metals. The technology of small-capacity incinerators, for use by a single medical facility, is often rudimentary. These installations are not recommended, since they may constitute a serious air pollution hazard to the surrounding area. Incineration is an option for certain types of HCW (and is the preferred method for some substances such as cytotoxins and other pharmaceuticals), but it needs to be carefully operated and controlled. Regulatory agencies in the United States and the European Union have adopted emissions limits for medical waste incinerators that include, among others, values for dioxins.

• Autoclaving involves heating waste material with steam in an enclosed container at high

pressure. At the appropriate levels of time (>60 min), temperature (>121°C), and pressure (100 kPa), effective inactivation of all vegetative microorganisms and most bacterial spores can be achieved. Preparation of material for autoclaving requires segregation to remove unsuitable material and shredding to reduce the individual pieces of waste to an acceptable size. Small autoclaves are common for sterilization of medical equipment, but a waste management autoclave can be a relatively complex and expensive system requiring careful design, appropriate segregation of materials, and a high level of operation and maintenance support. The output from an autoclave is nonhazardous material that can normally be landfilled with municipal waste. The resultant wastewater


stream needs to be disposed of with appropriate care and controls. Furthermore, large autoclaves may require a boiler with stack emissions that will be subject to control. At present, the use of autoclaving, chemical disinfection, or any other non-destructive technology like microwave or radiowave irradiation is not allowed for the treatment of special HCW such as organs, tissues, or amputated human body parts. Incineration or burial are the only accepted techniques for the treatment of such special HCWs.

• Microwave and radiowave irradiation involves the application of a high-energy

electromagnetic field that provokes the liquid contained within the waste, as well as the liquid cell material of microorganisms, to oscillate at high frequency, heat up rapidly, and eventually cause the destruction of all infectious components of the waste. The technique occurs in enclosed containers at atmospheric pressure and temperatures below the normal water boiling point. The waste passes through a preparative process of segregation to remove undesirable material. The waste is then triturated, pulverized, and compressed prior to its disinfection. Similar to the autoclaving technique, the output from a microwave or radiowave facility is considered nonhazardous and can be landfilled together with municipal waste. Since the technology does not involve the application of steam, there is a minimal generation of wastewater, and with the appropriate conditioning, the water can be recycled to the system.

• Chemical disinfection, used routinely in health care to kill microorganisms on medical

equipment, has been lately extended to the treatment of HCW. Chemicals (mostly strong oxidants like chlorine compounds, ammonium salts, aldehydes, and phenolic compounds) are added to the waste to kill or inactivate pathogens. This type of treatment is considered most suitable for treating liquid wastes such as blood, urine stools or hospital sewage, but solid and highly hazardous HCWs like microbiological cultures or sharps must undergo a relatively complex and expensive preparative process of segregation, shredding, and milling prior to the application of the chemical reagents. The technology requires special treatment of hazardous wastewater streams.

• Land deposition of HCW is performed in the same manner as solid industrial wastes, that

is, in a pit excavated in mature municipal waste at the base of the working face and immediately covered by a 2-meter-deep layer of fresh municipal waste. As an alternative, a specially constructed small fenced landfill or pit could be prepared on part of the site to receive only HCW. It should be covered immediately with soil after each load. For added health protection and odor suppression, it is suggested that lime be spread over the waste. In both cases, it is essential to cover the HCW layer well enough to prevent animals or scavengers from re-excavating it. Landfilling is considered as a “bottom of the list” option for disposal of HCW. It is only recommended when the economic situation of the country does not permit access to environmentally safer technologies, such as the ones previously described.

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